ARCHIVED - Review of the Policy Framework for Research Integrity

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During the past year, NSERC, SSHRC and CIHR (the agencies), along with the Association of Universities and Colleges of Canada (AUCC), have undertaken a review of the agencies’ policy framework for research and scholarly integrity, and financial accountability. The agencies and AUCC remain committed to continuous improvement in this important area, and are pleased to make the report on this review public. Internal steps have been taken to implement some of the recommendations stated in the report that are specific to the agencies; next steps, including possible changes to the policy framework, will involve consultation with institutions and stakeholders. The agencies and AUCC are committed to the highest standards of integrity in research and scholarship, and financial accountability.

Background

The agencies are responsible for adhering to federal laws and policies which dictate financial and other management practices, and which set accountability standards. The agencies have developed a policy framework that researchers and institutions are expected to meet in order to ensure integrity and accountability in the conduct of their research and in the use of grant and award funds.

In early May 2008, three cases related to research integrity and use of funds associated with NSERC grants, dating back to 2005 and 2006, were reported in the media.

The Minister of Industry subsequently requested that NSERC, SSHRC and AUCC review the integrity policy framework under the Memorandum of Understanding on the Roles and Responsibilities in the Management of Federal Grants and Awards. The review looked at which aspects of the framework were appropriate and sufficient, and which were not, including what short-term and long-term measures would be needed to improve the policy framework, its implementation and transparency.

The report was submitted to the Minister of Industry in October 2008. In January 2009, the Minister thanked NSERC, SSHRC and AUCC for the report and recommended that it be made public. CIHR provided input on the draft report and will participate in the development and implementation of an action plan based on the report. CIHR’s participation is essential, as the policy framework is shared by the three agencies. A working group of staff from the agencies and AUCC was established and has begun to follow up on the report’s recommendations.

The Issue

The agencies established the first federal research and scholarly integrity policy in Canada in 1994. The agencies do not have regulatory authority to investigate cases of alleged misconduct. The agencies promote integrity and will refer an allegation of scientific and scholarly misconduct to the researcher’s institution for investigation. Where research or scholarly misconduct is found to have occurred, the institution is committed, after completion of the investigation, to forward a report within 30 days to the agency involved. The agencies and institutions may decide to take certain actions, such as terminating funding or declaring a researcher ineligible from applying for future funding, where appropriate.

The integrity policy framework requires that recipient institutions promote integrity, properly investigate allegations, impose sanctions on their researchers and inform the appropriate agency of their findings of misconduct if agency funding is involved. Institutional research integrity policies continue to be reviewed and approved by the agencies prior to the institution becoming eligible to receive funding.

Each institution’s financial control framework for agency grants and awards is also reviewed. Institutions are required to advise the agencies of inappropriate use of grant funds, and to provide the agencies with access to all accounts, records and other grant or award information, as requested. When agencies’ policies are not adhered to, the agencies may require reimbursement of the grant account and the agencies and institutions may take certain actions, where appropriate. If criminal activity is suspected, such as fraud, the case is forwarded to the RCMP.

While the institutions and the agencies play a role in providing an environment that is conducive to promoting integrity and accountability, the researchers bear the primary responsibility for their behaviour. The vast majority of researchers conduct their research with rigour and integrity. Researchers agree, upon submission of a funding request, to adhere to agency policies on research and scholarly integrity, and financial management.

Highlights of the Report

Overall, the review of the agencies’ policies and procedures related to research integrity and the management of funds has shown that the framework is sound, and flexible enough to address a wide range of possible acts of misconduct. The review identified the need to improve certain areas of the existing research integrity and financial accountability framework. While the framework has not caused significant difficulties in handling cases of misconduct to date, the agencies agree that updating, harmonizing and clarifying policies and procedures would reduce the risk of problems occurring.

The report recommends a number of actions that can be grouped under four key areas:

1. Clarify the agencies’ role regarding integrity in order to determine a) whether the agencies are fulfilling all their responsibilities and exercising all their authorities, including holding the institutions and researchers fully accountable, and b) whether their current legislated roles, responsibilities and authorities are appropriate and sufficient for the level of oversight and accountability required.
2. Update and strengthen the current research and scholarly integrity policy in order to ensure that it reflects the highest standards of integrity and provides increased clarity of terms, roles and responsibilities.
3. Improve the effectiveness of the implementation of the policy and increase its transparency, in order to ensure that integrity cases are dealt with effectively and that stakeholders are well informed.
4. Update and strengthen the current financial policy in order to ensure that it reflects the highest standards of accountability and provides increased clarity of terms, roles and responsibilities.

Action Plan

The agencies are completing a review of their legislated roles, responsibilities and authorities in order to clarify their roles in promoting integrity in research and scholarship, and mitigating financial risks. This work will assist in deciding on next steps and future changes to the policy framework. The agencies will provide a public update on their findings by February 2010.

The agencies will work with stakeholders to improve transparency in the process and the communication and promotion of the highest standards in integrity and financial accountability. Presentations on integrity were done at meetings of the Canadian Association of University Research Administrators (CAURA) in the fall of 2008 and May 2009. Throughout the process, AUCC has kept its membership informed of developments. The agencies have also posted statistics on integrity cases on their respective web sites:  NSERC,  CIHR,  SSHRC. Future annual updates will provide standardized reporting of data. The agencies will endeavour to publish articles on lessons learned and best practices from their review of institutional policies and the handling of specific cases. Longer-term educational tools may include on-line tutorials on research integrity and financial accountability.

The agencies are harmonizing their own processes for reviewing cases, to ensure a consistent approach. The harmonized process is expected to be made public by February 2010. This process will be used to address allegations of non-compliance with the agencies’ research policies, such as integrity, financial, ethics and application instructions.

The agencies will continue to closely monitor the progress of investigations and will hold institutions accountable for adhering to the time lines stated in the institutions’ integrity policies. As part of longer-term work to be done on the revision to the agencies’ policy framework, they will work with institutions and other stakeholders to find ways to expedite and improve the institutional investigative process.

The major goal of this exercise is to review, consolidate, update and strengthen all research integrity policy documents, as well as those for financial accountability. This will include consulting with institutions, researchers and stakeholder groups. Most of this work will be completed by the end of 2011. To oversee the development and implementation of the new policy framework, the agencies are establishing an external advisory group whose membership and terms of reference will be communicated in February 2010.

In parallel with our work, the  Council of Canadian Academies is convening an expert panel on research integrity. The panel’s report should be finalized in the spring of 2010, and is expected to be a key element in the revision of the agencies’ policy framework.

The central point of contact for inquiries about the integrity report is Barbara Conway, Corporate Secretary, NSERC (613-995-5896), Barbara.conway@nserc-crsng.gc.ca).

Allegations and findings of misconduct have been rare in the Canadian research community, although it is likely that not all cases are reported. Regardless of their incidence, misconduct (or allegations of misconduct) can cause disproportionate harm to the public’s trust, members of the research community and the research enterprise. The current policy framework offers an inexpensive, flexible and self-regulating way for the agencies, researchers and institutions to promote integrity, prevent misconduct and address misconduct when it occurs. However, changes are needed to strengthen the framework.

The agencies and AUCC are committed to taking the appropriate actions to ensure that the highest standards of integrity and accountability are reflected in the agencies’ and institutions’ policies and procedures, and are rigorously implemented. The continuing implementation of the report’s recommendations will be done through consultation with the many stakeholders in the Canadian research community.