University Policies and Procedures Manual (previously Business Policies and Procedures Manual)

Responding to Alleged Violations of University Research Policies

UPPM 45.25

For more information contact:
   Office of Research

1.0   Overview

All University personnel, students, and others engaged in research and scholarship must comply with all applicable federal and state laws and regulations, grant and contract obligations, and University policies. These requirements are addressed in multiple University policies, procedures, and standards of conduct. While not an exhaustive list, many relevant policies are referenced in Section 6.0.

This policy sets forth procedures for responding to allegations of noncompliance with the laws, regulations, and policies applicable to the design, conduct, or reporting of research when there is no other established University compliance process that applies and/or when integration of multiple concurrent processes is necessary.

This policy is intended to supplement, not supersede, existing policies and procedures regarding the conduct of research at the University.

This policy does not:

  • Affect the authority conferred upon WSU compliance oversight offices to apply sanctions or take other corrective actions appropriate to their authority; or
  • Affect the authority of University officials, including the Vice President for Research (VPR), to halt any operation or activity that presents an unreasonable threat to health, safety, security, or property pursuant to UPPM 10.70.
  • Supersede any actions imposed by external regulatory bodies.

2.0   Applicability

This policy applies to all University personnel, students, and others engaged in research and scholarship at WSU, including but not limited to officials, faculty, staff, students, postdoctoral and other fellows, volunteers, and visiting scholars.

3.0   Organizational Responsibilities

3.1      VPR

The University’s VPR is the senior University official responsible for the development, administration, and enforcement of policies and directives governing research.

The VPR also serves as:

  • The Research Integrity Officer (RIO) responsible for addressing reports of alleged research misconduct (see UPPM 45.30); and
  • The delegated Institutional Official (IO) responsible for WSU’s research oversight committees:
    • Financial Conflict of Interest Committee (FCOI)
    • Institutional Animal Care and Use Committee (IACUC)
    • Institutional Biosafety Committee (IBC)
    • Institutional Review Board (IRB)
    • Radiation Safety Committee (RSC)
    • Reactor Safeguards Committee (RSC)

In addition to direct oversight of activities, each research oversight committee is responsible for evaluating and making recommendations regarding policies and procedures within the committee’s jurisdiction.

The VPR is also responsible for enforcement of University policies and directives, as well as sponsor requirements, pertaining to research activities that fall outside the scope of the UPPM 45.30 and the research oversight committees including, but not limited to, the following:

  • Appropriate data management and data security;
  • Laboratory safety;
  • Inter-institutional material transfer;
  • Processing of nonmonetary research agreements (e.g., confidentiality agreements, teaming agreements, and research collaboration agreements);
  • Reporting of international activities and support;
  • Hazardous materials shipping;
  • Compliance with University grant submission and management policies;
  • Use of unmanned aerial vehicles;
  • Controlled substances; and
  • Export controls and research security.

3.2      Other University Offices, Programs, and Processes

Conduct in violation of University policies and directives governing research may also fall within the purview of other University offices, compliance programs, and disciplinary processes (e.g., Internal Audit; Compliance and Risk Management; Environmental Health and Safety; the Center for Community Standards).

4.0   Procedure for Responding to Allegations

4.1      Reporting Allegations

All University personnel, students, and others engaged in research and scholarship at WSU are to report reasonable suspicion of noncompliance with laws, regulations, and policy applicable to the design, conduct, or reporting of research to the responsible body, committee, or individual. Self-reporting of noncompliance is required and allows for more rapid identification of corrective actions and resumption of research, when possible.

Section 6.0 includes policies, processes, and resources to aid in identifying the appropriate party to receive reports. If no other established University corrective action process applies or if there is confusion about the appropriate office to receive a concern or allegation of noncompliance, concerns must be reported either:

The Office of Research compliance hotline does not require that the reporting person identify themselves.

Efforts are taken to maintain confidentiality of reports of possible noncompliance for the duration of the review process to the extent possible and consistent with the University’s obligation to take appropriate action. The VPR or designee may share reports of possible noncompliance with the appropriate bodies or offices within the University on a need-to-know basis, such as the unit head, dean, campus chancellor, the Office of Human Resource Services (HRS), or the Office of the Provost.

4.2      Process

Because of the breadth of subject matter addressed by this policy, each report or concern is addressed by the VPR or a designee on a case-by-case basis. Upon receipt of a report or concern of noncompliance, the VPR or designee determines whether or not the concern is within the scope of the VPR’s authority; or another University corrective action process or oversight body. If a concern falls under the authority of an existing corrective action process or oversite body, the VPR or designee refers the concern to the appropriate recipient.

4.2.a   Under VPR’s Authority

If a report or concern of noncompliance does not fall within the scope of another established University corrective action process or oversight body, the VPR or designee assesses if the report:

  • Describes a reasonable suspicion of noncompliance with laws, regulations, or policy applicable to the design, conduct, or reporting of research; and
  • Is sufficiently credible and specific that potential evidence of noncompliance may be identified.

If both criteria are met, the VPR or designee selects an appropriate intervention based on the nature, scope, and potential impact of the noncompliance. For example, some concerns may be resolved by direct technical assistance from Office of Research personnel, while other matters may require additional information gathering to assess the accuracy of the report.

4.2.b   Under Multiple Corrective Action Processes or Oversight Bodies

If a report exceeds the scope of a single corrective action process or oversight body, the VPR or designee confers with the applicable programs to determine whether a collaborative or parallel resolution process would be appropriate.

5.0   Corrective Action and Referral

When the VPR or designee determines that noncompliance with policies and directives governing research has occurred and cannot be addressed by technical assistance, the VPR or designee may impose corrective action within the scope of the VPR’s authority and, where applicable, in accordance with UPPM 60.50 and WAC 504-26. (See also Section 6.0).

Research-specific corrective actions may include, but are not limited to:

  • Requiring specified training;
  • Mandating a corrective action plan and timeline;
  • Issuing a letter of concern or noncompliance;
  • Requiring notification to research support sponsors, co-authors, co-investigators, collaborators, and/or journal editors;
  • Mandating the return or destruction of improperly collected data;
  • Suspending supervision or mentoring of students;
  • Returning funds to the sponsoring entity;
  • Suspending laboratory privileges;
  • Suspending some or all research activities;
  • Requesting removal of the individual as a principal or co-investigator on specific or all research activities;
  • Suspending processing of proposals/applications to research sponsoring entities;
  • Formally withdrawing pending applications for research support;
  • Suspending or withholding sponsored activity (e.g., grant/contract) or operating funding;
  • Reporting to professional licensing boards, other institutions, state and/or federal agencies, or professional societies;
  • Making a public announcement; and/or
  • Requesting publication retractions or disassociation with published papers.

When appropriate and warranted, and if a unit or department is deemed in whole or part responsible, the department or unit may be held accountable for fees, charges, fines, or expenses incurred or resulting from or related to any such violation or noncompliance.

5.1      Other or Additional Actions

Depending upon the circumstances, the VPR may recommend that HRS, the appointing authority, the Provost’s Office, or other offices initiate other or additional actions, including potential disciplinary action in accordance with any applicable employee, faculty, or student disciplinary processes.

5.2      Variation from Procedures in This Policy

Some circumstances may dictate variation from the procedures described in this policy, if deemed in the best interests of the University and, if applicable, the federal sponsor. Any variation also must ensure fair treatment of the person or persons alleged to be noncompliant with University or sponsor requirements.

The VPR or designee must approve any significant variation in advance.

6.0   Resources and Related Policies

Note: With appreciation, WSU acknowledges this policy was modeled on the University of Louisville’s policy.

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Revisions:  Nov. 2024 – new policy (Rev. 637)