How are research integrity complaints handled in Australia?

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Most researchers are honest and their work is a worthwhile addition to the scholarly record. However, a significant percentage of researchers are engaged in questionable practices or producing work lacking integrity. For example, Bik and colleagues have estimated ~2% of the biomedical literature is affected by image manipulation problems. Adam Day, who runs the Papermill Alarm, has estimated that 2% of the literature has been paper milled. Prevalence studies have also found similar or even higher rates of research misconduct.

Given the quite high prevalence of unethical behaviour, how is research integrity handled in Australia? How do you make an effective complaint or what can you expect if a complaint is made about you?

I am a former researcher and a former research integrity officer and am here to outline what happens when a complaint is made to an Australian university. These processes may be different in your country so find out what they are from your local integrity or governance officer (or similar).

Australia’s Research Integrity Framework

Researchers at Australian universities are required to follow the Australian Code for the Responsible Conduct of Research (‘the Code’). The Code outlines several very reasonable principles and responsibilities that researchers are required to follow and uphold, such as Honesty, Transparency and Fairness.

Each Australian university will either have a policy that essentially copies and pastes from the national Code or a policy that requires researchers to comply with the national Code. Failure to uphold the principles and/or responsibilities in the Code are classified as ‘breaches’, which range from ‘minor’ to ‘major and serious’. Research ‘misconduct’ is defined as a ‘major and serious’ breach that is also ‘intentional, reckless or negligent’.

What can be considered research ‘misconduct’ in Australia can therefore be quite broad. For comparison, the United States defines research misconduct as plagiarism, fabrication or falsification. However, research integrity problems are much broader than plagiarism, fabrication and falsification, so a researcher could do something in the US that isn’t considered misconduct, like failing to get ethics approval, and that could be considered misconduct in Australia.

Assessing and Investigating Potential Breaches

The partner of the national Code is the Guide to Managing and Investigating Potential Breaches of the Australian Code for the Responsible Conduct of Research (the ‘Guide’ – 0.62 MB PDF download). The Guide outlines three main steps in dealing with a potential breach: Initial Assessment, Preliminary Assessment and Investigation. However, as its name implies, it is a guide and there is a bit of variation between universities in how they have tailored and implemented the Guide, depending on their size, policy history and how much guidance they have received from Australian Research Integrity Committee (ARIC) reviews of their cases.

Once a complaint is received, it undergoes an ‘Initial Assessment’. The Initial Assessment is fairly straightforward and is more or less a complaint triage step, so I will focus mostly on the Preliminary Assessment and Investigation.

The “Preliminary Assessment”

In my view, ‘Preliminary Assessment’ can be a misnomer because the detail and rigour of this step varies extremely widely. For example, one interpretation is that if the complaint or allegation could be misconduct, then the case should progress to the next step. However, a literal and consistent application of this rule would mean that essentially any complaint that alleged deliberate falsification of data would go straight to a misconduct Investigation Panel. Therefore, most universities do some kind of fact-finding assessment at this stage.

The fact-finding work is done by an ‘Assessment Officer’. In some institutions, especially smaller universities, this might be an academic staff member. Elsewhere, it may be a professional staff member with a background in law, policing or research and training in conducting investigations. Regardless of their background, their role might be to outline the allegations to the researcher(s) concerned (the ‘respondent(s)’), make enquiries with other researchers or journals and seek expert advice. They then write a report and submit it to a more senior person, the ‘Designated Officer’ who decides whether a (potential) breach has occurred and, if so, how serious it is.

Investigation Panel

Most complaints result in findings of no breach or minor (potential) breaches that can be resolved with corrective actions (i.e., to fix whatever went wrong). However, a small number of complaints are considered potential research misconduct. This is where things get even more complicated.

The Designated Officer refers the matter to the ‘Responsible Executive Officer’, an even more senior person in the University, such as a Deputy Vice-Chancellor. The respondent(s) might then be offered a chance to admit or deny misconduct, to provide additional evidence and be invited to appear before the Investigation Panel.

Assembling an Investigation Panel is like trying to organise peer review (which is already experiencing shortages), except harder. There’s little to no recognition for the work and the volume of material is much greater. For example, while editors may struggle to recruit reviewers for a single unpublished manuscript, a research integrity office needs to recruit academic experts for cases that might span dozens of published papers.

If the Preliminary Assessment was akin to a police investigation, the Investigation stage is more like a court hearing, where the complaint or allegations are reviewed again and the respondent has another opportunity to be heard before another report is written and sent to the Responsible Executive Officer to make a decision.

Appeals

If it is found the respondent(s) committed research misconduct, they can appeal the decision internally to their university.

Both respondents and complainants can appeal to the Australian Research Integrity Committee (ARIC), which operates out of Australian Research Council and National Health and Medical Research Council. ARIC handles a small number of reviews – up to a dozen – each year, which is less than one review per Australian university. ARIC will typically review a case after it has concluded at a university but will occasionally review ongoing cases if it believes there is a compelling reason.

Making an Effective Complaint

The management and investigation of research integrity complaints in Australia follows a long and complicated process. But as someone who has conducted fact-finding in real research integrity cases, here are my tips (YMMV) for complainants to help them be effective:

  1. Try to understand the process or get advice (e.g., from a Research Integrity Advisor). The process isn’t simple, so know what to expect.
  2. Provide the full detail of your complaint and as much supporting evidence as possible (see also, tips from the Commonwealth Ombudsman). I would encourage complainants to provide a full account because if additional allegations are raised during an ongoing Preliminary Assessment, the process may essentially start again, creating delays or preventing decision makers from seeing relevant facts together.
  3. Be clear about your interest in the case going forward. Do you want to be anonymous? Are you willing to be contacted for clarification? Some institutions provide draft reports (such as the Preliminary Assessment Report) to complainants and/or respondents to comment on potential errors. Do you want to take part or just submit and forget?
  4. Be patient. I suspect that addressing a PhD’s worth of misconduct takes more than a PhD’s worth of time and effort. And cases aren’t always as simple as they appear.

Coping as a Respondent

Similarly, if you are the subject of a complaint, you have rights. Here are some of my suggestions for how to be effective as a respondent (again, YMMV; see also this law firm’s blog):

  1. Try to understand the process or get advice (e.g., from a Research Integrity Advisor or lawyer). While you can ask the Assessment Officer about process, remember, they are not your friend – their job is to investigate your conduct.
  2. Communicate clearly and respectfully. Explain things so a non-expert can understand and provide supporting evidence. Be respectful because you’re better off explaining why your conduct met the principles or responsibilities you allegedly breached than insulting people or bragging about how eminent you are.
  3. Be honest. Professional investigators are trained to figure out if you are lying. Minor breaches are usually addressed through corrective (i.e., not disciplinary) action. So, depending on your circumstances, you’re probably better off admitting the truth or staying silent than lying.
  4. Access support. Being subject to any workplace investigation is stressful, especially when the subject matter is complex and the process is long and difficult. Consider using the supports available to you, whether from a university service, student union/guild, Employee Assistance Program, or your own social networks.

Research Integrity: It’s Complicated!

Research integrity complaints have a long and difficult journey (7:40 streaming video) under Australia’s national framework (which is also separate to the journal processes). Researchers are required to comply with a national Code and complaints are managed in three steps under the Guide. An ‘Initial Assessment’ triages complaints, then a ‘Preliminary Assessment’ occurs, analogous to a police investigation. For serious matters, an ‘Investigation’ involves a panel of experts hearing the case, akin to a court. It’s not easy for anyone involved, which is why my most important advice is: do your research with honesty and integrity so that you’ll never be subject to it.

And if you ever make a complaint, be prepared to wait.

Author Bio: Shaun Khoo is a project manager at UNSW Sydney.

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