Promoting Integrity in Research
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Assurance - AgreementsStudy of Affiliation Agreements Used by Institutions to Comply with the Requirements of Their Misconduct Assurance (1999)
Thirty-four institutional policies were found to be in compliance, and 33 institutional policies required some revision, as a part of our review. In six cases, the policies provided were for an organization other than the parent, or there were separate policies for the parent and affiliate. Table 5 - Affiliation Acknowledgment
Each policy was reviewed to determine whether there was any reference to the affiliation arrangement. This question is slightly different than a previous question that asked whether the affiliated institution was included in the policy title. Only 13 of 73 institutional policies (17%) have any reference in them to the affiliate organizations. Of that number, there was some evidence in eight policies that the affiliate organization accepted the arrangement. CONDUCT OF THE INQUIRY AND INVESTIGATION The policies were reviewed to determine whether the conduct of the inquiry and investigation were centralized at the parent level, decentralized at the affiliate level, or some combination of each. Table 6 - Conduct of the Inquiry
Better than half (43 of 73; 59%) of the inquiries were handled at the parent level. Only 19% (14 of 73) were handled at the affiliate level, while in the remaining 16 cases, the policies were not specific enough to make that determination. Other questions regarding the inquiry followed the same pattern: the contact person was primarily from the parent - 55% (40/73), the individual initiating the inquiry was associated with the parent in 56% of the cases (41/73), and the deciding official was also primarily associated with the parent - 56% (41/73). Where the inquiry was held at the affiliate level, the pattern was consistent: the contact person (21%) , the person initiating the inquiry (18%), and the deciding official (16%) were at the affiliate level. In approximately 25% of the cases, this information was difficult to evaluate, as the title and description of the responsible officials with a role in the inquiry and investigation were not specific enough to be positively identified with either the parent or the affiliate. Table 7 - Conduct of Investigation
The pattern for the conduct of the investigation was similar to that of the inquiry. The investigation was handled at the parent level in 59% of the policies (43 of 73), and the deciding official was associated with the parent in 60% (44 of 73) of the cases. Investigation at the affiliate level were identified on only 9 of 73 policies (12%), and the deciding official at this level could only be found in 10 policies (14%). The level of the official responsible for the investigation process could not be determine in 25% of the policies. OTHER ISSUES The policies were reviewed to determine whether the parent institution formally distributed the policies to the affiliated institutions. Table 8 - Distribution of Policies by Parent Yes: 9 No: 1 Undetermined: 63 There was evidence in the policies that this distribution occurred at only nine parent/affiliate groups. In all but one case where the policies were not distributed, the policies were silent on the issue of distribution. Table 9 - Role of Affiliate in Naming Inquiry/Investigation Committees Full or Complete: 4 Primary: 1 None: 9 Unknown: 59 In only five cases (7%) did the policies acknowledge and describe a role for the affiliates in naming the inquiry and/or investigation panel. In nine cases (12%) the policies were clear that this was a responsibility at the parent level. In the majority of cases (71%), the policies were simply not clear on this topic. It is also likely that the high percentage of institutions that handle both the inquiry and investigation at the parent level (approximately 60%) simply have not made any accommodation for the affiliate, and more likely, were not designed as a multi-institutional procedure. The review could only identify eight instances (11%) in which officials from the affiliate institutions had membership on either the inquiry or investigation committees. A question was asked regarding who handled appeals, and the policies for the most part did not identify the official specifically enough to determine whether they were from the parent or affiliate. However, the question did yield more relevant information regarding the existence of an appeals process within the institutional policies. In only nine cases (12%) were there any provisions for an appeal. COMPLAINANT AND RESPONDENT PROTECTION The review of the policies also disclosed that only 31 of 73 (42%) of institutions had any reference to the protection of whistleblowers, and only a slightly larger number (37 of 73 - 51%) of the institutions identified any official as responsible for restoring the reputation of the respondent. These percentages are not inconsistent with the results of other policy reviews. CONCLUSION There is little evidence that any institutional policies were modified to account for the existence of the parent/affiliate relationship with ORI. For institutions that did have multi-institutional policies, they were likely developed because of the institutional relationships that existed irrespective of any interaction with ORI. For example, some universities have policies that cover several campuses; health department policies often include regional facilities. When institutions established an affiliation for the purpose of reporting to ORI, very few, if any, modified their policies to reflect this arrangement. Part of this review involved reviewing policies for compliance with the Federal regulation, and determining whether the policies of the parents (in the absence of separate affiliate policies) were applicable to the affiliates, and whether the affiliate would formally adopt the policies of the parents. This objective, with only a few exceptions, has been accomplished. Institutions have made their policies compliant with the Federal regulation following ORI review; affiliates are covered by compliant policies, either as part of the parent's process, or with a policy of their own. The review did highlight the type of multi-institutional policies that are
effective. There are three main models. The first model involves each institution
having separate policies for dealing with misconduct at that facility. The affiliation
agreement is only for the purpose of reporting to ORI. The second model involves
a parent policy that makes reference to the affiliated organizations, and makes
accommodations for the separate organizational structures. The third model involves
aspects of the first two: there is an overall policy that covers the entire
multi-organizational group, with separate procedures developed by each of the
affiliates to account for their separate organizational structure. In one case,
the parent developed the procedure that would be effective for each affiliated
unit until that affiliate developed a procedure of its own.
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