tutions that receive Public Health Service (PHS) research funds to adopt an administrative process for reviewing reports of scientific fraud. This legislation also authorized the secretary of the Department of Health and Human Services (DHHS) to adopt regulations to require assurances from PHS grantees that such an administrative process was in place (DHHS, 1986). In fulfilling its obligation under the legislation, the PHS issued interim guidelines in 1986 on policies and procedures for handling alleged misconduct. Educational and scientific societies such as the Association of American Universities, the Association of American Medical Colleges, and the American Association for the Advancement of Science provided forums to review progress by the research institutions in complying with the new regulatory requirements. In addition, educational, legal, and scientific organizations suggested approaches to addressing allegations of misconduct in science, assessing institutional experience in handling misconduct complaints, and providing national and regional forums for the exchange of information and experience in this area (AAU, 1983; AAMC, 1982; AAAS-ABA, 1989).
In 1989 the DHHS's Office of Inspector General (OIG) reported that most of the research-intensive universities (institutions with 100 or more PHS awards) had adopted formal policies and procedures for addressing allegations of misconduct in science but that only 22 percent of all PHS institutional grantees had such policies and procedures (DHHS, 1989d). The OIG report suggested that many of the institutional policies and procedures were limited in scope and that most did not require notification to the National Institutes of Health (NIH) as the 1986 interim guidelines had suggested (DHHS, 1989d).2 The report found that some grantee institutions had been waiting for final PHS regulations to be promulgated before developing their own policies and procedures.
Following congressional hearings that criticized university and agency responses to allegations of misconduct, the PHS, in 1989, published final regulations requiring all applicant and grantee institutions to adopt misconduct policies and procedures (42 C.F.R. 50).3 Although the regulations provide general direction about procedural elements (such as requirements for an inquiry, an investigation, disclosure, and notification), the specific content and scope of misconduct policies and procedures remain at the discretion of the research institutions. The procedural elements have been the subject of extensive debate and discussion over the past 3 years as more experience has been acquired by research institutions and federal agencies in the implementation of the regulations.