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Misconduct in Research

Federal law and Carleton’s institutional mission require that Carleton have policies and procedures for dealing with research misconduct, or alleged research misconduct, by any member of the Carleton community, including faculty, staff, and students. This document describes those policies and procedures.

Carleton expects academic integrity from all members of its community, including all faculty, staff, and students, at all times and in all circumstances.  Carleton encourages anyone who believes they have witnessed research misconduct by a Carleton community member to report that activity.  Reports of suspected research misconduct should be made to the Associate Provost whose portfolio includes compliance duties such as oversight of the Institutional Animal Care and Use Committee (IACUC) and the Institutional Review Board (IRB) or to the Provost & Vice President for Academic Affairs (Provost).  Anyone making such a report should be aware that if an investigation takes place, the name of the complainant cannot be kept from the person accused of misconduct.  The Associate Provost above will be happy to discuss a potential report in a confidential manner before a formal report is made.

See this page on Grants Office website for definitions of terms in these policies and procedures.

A. Scope and Applicability

These policies and procedures apply to all members of the Carleton community, including faculty, staff, and students.

These policies and procedures apply to all allegations of research misconduct against any member of the Carleton community, including those involving any of the following.

1. Applications or proposals for federal support for research or related educational activities.
2. Federally supported research.
3. Federally supported research training programs.
4. Activities related to the federally supported research such as the dissemination of research information.
5. Research records produced during federally supported research, research training, or related activities.
6. Research proposed, performed, reviewed, or reported, as well as any research record generated from that research, regardless of whether an application or proposal for federal funds resulted in an awarded grant, contract, cooperative agreement, subaward, or other form of support.

These policies and procedures apply only to research misconduct occurring within six years of the date the Department of Health and Human Services (DHHS or HHS) or Carleton receives an allegation of research misconduct, with the following exceptions.

1. The six-year time limitation does not apply if the respondent continues or renews any incident of alleged research misconduct that occurred before the six-year period through the use of, republication of, or citation to the portion(s) of the research record alleged to have been fabricated, falsified, or plagiarized, for the potential benefit of the respondent.
2. The six-year time limitation does not apply if the Office of Research Integrity (ORI) or Carleton, following consultation with ORI, determines that the alleged research misconduct, if it occurred, would possibly have a substantial adverse effect on the health or safety of the public.

B. Roles

Throughout these policies and procedures, the Institutional Deciding Official (IDO) is the Provost & Vice President for Academic Affairs and the Research Integrity Officer (RIO) is the Associate Provost whose portfolio includes compliance duties such as oversight of the Institutional Animal Care and Use Committee (IACUC) and the Institutional Review Board (IRB).

C. Procedures for Addressing Allegations of Research Misconduct

Allegations of research misconduct are addressed through a three-stage process:  Assessment, Inquiry, and Investigation, each of which is described in detail below. 

1. Assessment

The purpose of an Assessment is to determine whether an allegation warrants an Inquiry. An Assessment is intended to be a review of readily accessible information relevant to the allegation.

Upon receiving an allegation of research misconduct, the recipient of the allegation (the Provost or and Associate Provost) will notify the RIO and the IDO.  The RIO will promptly determine whether the allegation (a) falls within the definition of research misconduct under 42 CFR Part 93, (b) is within the applicability criteria of 42 CFR Part 93 § 93.102, and (c) is credible and specific enough to identify and sequester potential evidence.

If the RIO determines that the allegation meets all three of these criteria, they will promptly (a) document the assessment, (b) initiate an Inquiry, and (c) sequester all research records and other evidence. The RIO will arrange for the assessment documentation to be retained securely for seven years after completion of the misconduct proceedings.

If the RIO determines that the allegation does not meet one or more of the criteria required to proceed to an inquiry, they will write sufficiently detailed documentation to permit a later review by ORI of why Carleton did not proceed to an inquiry, share this documentation with the IDO, and arrange for this documentation to be retained securely for seven years.

2. Inquiry

The purpose of an Inquiry is to determine whether an allegation warrants an Investigation. An Inquiry does not require a full review of all related evidence. Carleton will complete any Inquiry within 90 days of initiating it unless circumstances warrant a longer period, in which case the RIO will sufficiently document the reasons for exceeding the time limit in the Inquiry report.   An Inquiry consists of steps (a) though (e) below, which will be carried out by the RIO.

(a) Sequestering Evidence and Notifying the Respondent

Before or at the time of notifying the respondent(s), the RIO will obtain the original or substantially equivalent copies of all research records and other evidence that are pertinent to the proceeding.  They will inventory these materials, sequester them in a secure manner, and arrange for them to be retained for seven years. The RIO will also obtain, inventory, and securely sequester any additional evidence that becomes known during the course of the Inquiry.

At the time of or before beginning the Inquiry, the RIO will make a good-faith effort to notify the respondent(s), in writing, that an allegation of research misconduct has been raised against them, the relevant research records have been sequestered, and an Inquiry will be conducted to decide whether to proceed with an investigation. If additional allegations are raised, the RIO will notify the respondent(s) in writing. When appropriate, the RIO will give the respondent(s) copies of, or reasonable supervised access to, the sequestered materials.

If additional respondents are identified during the Inquiry, the RIO will provide written notification to the new respondent(s). All additional respondents will be given the same rights and opportunities as the initial respondent. Only allegations specific to a particular respondent will be included in the notification to that respondent.

(b) Convening the Committee and Ensuring Neutrality

The RIO will determine whether to convene a committee to conduct the Inquiry or to conduct the Inquiry themselves. 

If the RIO convenes a committee to conduct the Inquiry then the committee will include at least one faculty member and at least one staff member, and will have at most four members. All members of the committee will have experience conducting, mentoring, or supporting research in fields related to the field in which the alleged misconduct occurred. Retired faculty are eligible to serve on an Inquiry Committee and all non-retired faculty members on the committee will be tenured.

If the RIO convenes a committee to conduct the Inquiry then the RIO will vet all committee members for conflicts of interest, ensure all committee members understand their commission, keep the identities of respondents, complainants, and witnesses confidential, and conduct the research misconduct proceedings in compliance with the Public Health Service (PHS) regulation. The Inquiry Committee (or the RIO if there is no Inquiry Committee) will utilize subject matter experts as needed to assist in the Inquiry.

(c) Determining Whether an Investigation Is Warranted

The Inquiry Committee (or the RIO if there is no Inquiry Committee) will conduct a preliminary review of the evidence. In the process of fact-finding, they may interview the respondent and/or witnesses, possibly including the complainant. An Investigation is warranted if (a) there is a reasonable basis for concluding that the allegation falls within the definition of research misconduct under 42 CFR Part 93 and (b) preliminary information-gathering and fact-finding from the Inquiry indicates that the allegation may have substance.

The Inquiry Committee (or the RIO if there is no Inquiry Committee) will neither determine whether research misconduct occurred nor assess whether the alleged misconduct was intentional, knowing, or reckless.  These determinations are made in the Investigation.

(d) Documenting the Inquiry

At the conclusion of the Inquiry, regardless of whether an Investigation is warranted, the Inquiry Committee (or the RIO if there is no Inquiry Committee) will prepare a written Inquiry Report. The Inquiry Report will include the following.

1. The names, professional aliases, and positions of the respondent(s) and complainant.
2. A description of the allegation(s) of research misconduct.
3. Details about any federal funding involved, including any grant numbers, grant applications, contracts, and publications listing this support.
4. The composition of the Inquiry Committee, if used, including name(s), position(s), and subject matter expertise.
5. An inventory of sequestered research records and other evidence and description of how sequestration was conducted.
6. Transcripts of any interviews, if transcribed.
7. Inquiry timeline and procedural history.
8. Any scientific or forensic analyses conducted.
9. For each allegation, a recommendation of whether an Investigation is warranted or not, and the basis for that recommendation.
10. Any comments on the Inquiry Report by the respondent(s) or the complainant. (See below.)
11. Any institutional actions implemented, including internal communications or external communications with journals or funding agencies.
12. Documentation of potential evidence of honest error or difference of opinion.

(e) Completing the Inquiry

The RIO will give the respondent(s) a copy of the draft Inquiry Report for review and comment. The RIO may, but is not required to, provide relevant portions of the report to the complainant for comment. The respondent will provide any comments within seven calendar days of receiving the draft Inquiry Report.  If the RIO provides portions of the report to the complainant for comment then the complainant will provide any comments within seven calendar days of receiving portions of the report. The RIO will include any comments received from the respondent(s) or complainant in the final report, or indicate in the final report that no comments were received.

The RIO will notify the respondent(s) of the Inquiry’s final outcome and provide the respondent(s) with copies of the final Inquiry Report, the PHS regulation, and these policies and procedures. The RIO may, but is not required to, notify a complainant whether the Inquiry found that an Investigation is warranted. If the RIO provides notice to one complainant in a case, then they will provide notice, to the extent possible, to all complainants in the case.

If the Inquiry Committee (or the RIO if there is no Inquiry Committee) determines that an investigation is not warranted, the RIO will keep sufficiently detailed documentation to permit a later review by ORI of why Carleton did not proceed to an Investigation, arrange for these records to be stored in a secure manner for at least seven years after the termination of the Inquiry, and provide them to ORI upon request.

If the Inquiry Committee (or the RIO if there is no Inquiry Committee) determines that an Investigation is warranted, the RIO will, within 30 days, (a) provide written notice to the respondent(s) of the decision to conduct an Investigation of the alleged misconduct, including any allegations of research misconduct not addressed during the Inquiry and  (b) provide ORI with a copy of the Inquiry Report.  Also within 30 days of the determination that an Investigation is warranted, but after providing written notice to the respondent(s), the RIO will begin the Investigation.

The RIO may, but is not required to, notify the complainant that there will be an Investigation of the alleged misconduct.  If the RIO provides notice to one complainant in a case, then they will provide notice, to the extent possible, to all complainants in the case.

3. Investigation

The purpose of an Investigation is to formally develop a factual record, pursue leads, examine the record, and recommend finding(s) to the IDO.  The IDO will make the final decision, based on a preponderance of evidence, on each allegation and any institutional actions. As part of the Investigation, the RIO will diligently pursue all significant issues and relevant leads, including any evidence of additional instances of possible research misconduct, and continue the Investigation to completion.

(a) Notifying the Respondent(s) and Sequestering Evidence

If any additional respondent(s) are identified during the Investigation, the IDO will notify them of the allegation(s) and provide them an opportunity to respond consistent with the PHS regulation. If the IDO identifies additional respondents during the Investigation, they may choose to either conduct a separate inquiry or add the new respondent(s) to the ongoing investigation. The IDO will obtain the original or substantially equivalent copies of all research records and other evidence, inventory these materials, sequester them in a secure manner, and arrange for them to be retained for seven years after the conclusion of the proceeding or of any HHS proceeding, whichever is later.

(b) Convening an Investigation Committee

The IDO will convene an Investigation Committee, which will include at least one faculty member and at least one staff member, and will have at most four members. All members of the committee will have experience conducting, mentoring, or supporting research in fields related to the field in which the alleged misconduct occurred. Retired faculty are eligible to serve on an Investigation Committee and all non-retired faculty members on the committee will be tenured.  If there was an Inquiry Committee then members of the Inquiry Committee are eligible to serve on the Investigation Committee, but not required to do so.

The IDO will vet all members of the Investigation Committee for conflicts of interest and will ensure that the members understand their responsibility to conduct the research misconduct proceedings in compliance with the PHS regulation. The Investigation Committee will conduct interviews, pursue leads, and examine all research records and other evidence relevant to reaching a decision on the merits of the allegation(s). The Investigation Committee will make diligent efforts to ensure that the investigation is thorough, sufficiently documented, and impartial and unbiased to the maximum extent practicable. The IDO will notify the respondent in writing of any additional allegations raised against them during the investigation.

(c) Conducting Interviews

The Investigation Committee will interview each respondent, complainant, and any other available person who has been reasonably identified as having information regarding any relevant aspects of the Investigation, including witnesses identified by the respondent(s). The Investigation Committee will

• number all relevant exhibits and refer to any exhibits shown to the interviewee during the interview by that number,
• record and transcribe interviews during the investigation,
• make the transcripts available to the interviewee for correction, and
• include the transcript(s) with any corrections and exhibits in the institutional record of the Investigation.

The respondent(s) will not be present during the witnesses’ interviews, but the Investigation Committee will provide the respondent(s) with a transcript of each interview, with redactions as appropriate to maintain confidentiality.

(d) Documenting the Investigation

The Investigation Committee will complete all aspects of the investigation within 180 days. The committee will conduct the investigation, prepare a draft investigation report for each respondent, and provide the opportunity for respondents to comment. Each respondent will provide any comments within seven calendar days of receiving the draft investigation report. The Investigation Committee may, but is not required to, provide relevant portions of the report to the complainant for comment. If the committee provides portions of the report to the complainant for comment then the complainant will provide any comments within seven calendar days of receiving portions of the report. The Investigation Committee will include any comments received from the respondent(s) or complainant in the final report, or indicate in the final report that no comments were received.

The RIO will document the IDO’s final decision and transmit the institutional record (including the final investigation report and IDO’s decision) to ORI. If the Investigation takes more than 180 days to complete, the IDO will ask ORI in writing for an extension and document the reasons for exceeding the 180-day period in the investigation report.

Each Investigation Report will include the following.

1. A description of the nature of the allegation(s) of research misconduct, including any additional allegation(s) addressed during the research misconduct proceeding.
2. A description and documentation of the PHS support, including any grant numbers, grant applications, contracts, and publications listing PHS support. This documentation will include known applications or proposals for support that the respondent has pending with PHS and non-PHS Federal agencies.
3. A description of the specific allegation(s) of research misconduct for consideration in the Investigation of the respondent.
4. The composition of the Investigation Committee, including name(s), position(s), and subject matter expertise.
5. An inventory of sequestered research records and other evidence, except records the Investigation Committee did not consider or rely on. This inventory will include manuscripts and funding proposals that were considered or relied on during the Investigation. The inventory will also include a description of how any sequestration was conducted during the Investigation.
6. Transcripts of all interviews conducted.
7. Identification of the specific published papers, manuscripts submitted but not accepted for publication (including online publication), PHS funding applications, progress reports, presentations, posters, or other research records that contain the allegedly falsified, fabricated, or plagiarized material.
8. Any scientific or forensic analyses conducted.
9. A copy of these policies and procedures.
10. Any comments made by the respondent(s) and complainant on the draft investigation report and the Committee’s consideration of those comments.
11. A statement for each separate allegation stating whether the Committee recommends a finding of research misconduct.

For each allegation for which the Committee recommends a finding of research misconduct, the Investigation Report will (a) identify the individual(s) who committed the research misconduct, (b) indicate the nature of the misconduct (e.g., falsification, fabrication, plagiarism), (c) indicate whether the misconduct was committed intentionally, knowingly, or recklessly, (d) identify any significant departure from the accepted practices of the relevant research community (e) indicate that the allegation was proven by a preponderance of the evidence, (e) summarize the facts and analysis supporting the conclusion, (f) consider the merits of any explanation by the respondent, (f) identify any specific PHS support involved, and (g) state whether any publications need correction or retraction.

For each allegation for which the Committee does not recommend a finding of research misconduct, the Investigation Report will provide a detailed rationale for the conclusion.

(e) Completing the Investigation

The IDO will give the respondent a copy of the draft Investigation Report and, concurrently, a copy of, or supervised access to, the research records and other evidence that the Investigation Committee considered or relied on. The respondent will submit any comments on the draft report to the IDO within 30 days of receiving the draft investigation report. If the IDO chooses to share a copy of the draft investigation report or relevant portions of it with the complainant(s) for comment, the complainant’s comments will be submitted within 30 days of the date on which they received the report. The Investigation Committee will add any comments received from the complainant(s) to the Investigation Report.

(f) IDO Review of the Investigation Report

The IDO will review the investigation report and make a final written determination of whether research misconduct occurred and, if so, who committed the misconduct. In this statement, the IDO will include a description of relevant institutional actions taken or to be taken.

(f) Appealing the Decision of the IDO

The determination of the IDO is final and is not subject to appeal.

(g) Creating and Transmitting the Institutional Record

After the IDO has made a final determination of research misconduct findings, they will add their written decision to the Investigation Report and organize the institutional record in a logical manner.

The institutional record consists of the records that were compiled or generated during the research misconduct proceeding, except records that were not relied on. These records include documentation of the assessment, a single index listing all research records and evidence, the Inquiry Report and Investigation Report, and all records considered or relied on during the Investigation. The institutional record also includes the IDO’s final decision and any information the respondent provided to the institution. The institutional record must also include a general description of the records that were sequestered but not considered or relied on.

After the IDO has made a final written determination, they will promptly transmit the institutional record to ORI.

D. Roles, Rights, and Responsibilities

Carleton College’s General Responsibilities

To the extent possible, Carleton will limit disclosure of the identity of respondents, complainants, and witnesses while conducting the research misconduct proceedings to those who need to know, inform all institutional members about these policies and procedures, and make these policies and procedures publicly available. This limitation on disclosure no longer applies once Carleton has made a final determination of its research misconduct findings. Carleton will respond to each allegation of research misconduct under 42 CFR Part 93 in a thorough, competent, objective, and fair manner. Carleton will take all reasonable and practical steps to ensure the cooperation of respondents and other institutional members with research misconduct proceedings, including, but not limited to, their providing information, research records, and other evidence. Carleton agrees to cooperate with ORI during any research misconduct proceeding or compliance review, including addressing deficiencies or additional allegations in the institutional record if directed by ORI and to assist in administering and enforcing any HHS administrative actions imposed on institutional members. Carleton may also take steps to manage published data or acknowledge that data may be unreliable.

Carleton’s Responsibilities During and After a Research Misconduct Proceeding

Except as may otherwise be prescribed by applicable law, Carleton will maintain confidentiality for any records or evidence from which research subjects might be identified and will limit disclosure to those who need to know to carry out a research misconduct proceeding. Before or at the time of notifying the respondent of the allegation(s) and whenever additional items become known or relevant, Carleton will promptly take all reasonable and practical steps to obtain all research records and other evidence and sequester them securely. Carleton will ensure that the institutional record contains all required elements, i.e., research records that were compiled and considered during the proceedings, assessment documentation, and inquiry and/or investigation reports. Upon completion of the inquiry, Carleton will provide ORI with the complete inquiry report and add it to the institutional record. Carleton will maintain the institutional record and all sequestered research records and other evidence in a secure manner for seven years after completion of the institutional and/or HHS proceeding.

Carleton will provide information related to the alleged research misconduct and proceedings to ORI upon request and transfer custody or provide copies of the institutional record or any component of it and any sequestered evidence to HHS, regardless of whether the evidence is included in the institutional record. Additionally, Carleton will promptly notify ORI of any special circumstances that may arise.

Disclosure of the identity of respondents, complainants, and witnesses while Carleton is conducting the research misconduct proceedings is limited to those who need to know, which Carleton will determine consistent with a thorough, competent, objective, and fair research misconduct proceeding, and as allowed by law. Those who need to know may include institutional review boards, journals, editors, publishers, co-authors, and collaborating institutions.

Carleton’s Responsibilities to the Complainant(s)

Carleton will provide confidentiality consistent with 42 CFR Part 93 for all complainants in a research misconduct proceeding. Carleton will also take precautions to ensure that individuals responsible for carrying out any part of the research misconduct proceeding do not have potential, perceived, or actual personal, professional, or financial conflicts of interest with the complainant(s). Carleton agrees to take all reasonable and practical steps to protect the positions and reputations of complainants and to protect these individuals from retaliation by respondents and/or other institutional members. If Carleton chooses to notify one complainant of the inquiry results in a case, it will notify all complainants, to the extent possible.

Carleton’s Responsibilities to the Respondent(s)

As with complainants, Carleton will provide confidentiality consistent with 42 CFR Part 93 to all respondents in a research misconduct proceeding. Carleton will make a good-faith effort to notify the respondent(s) in writing of the allegations being made against them. Carleton will take precautions to ensure that individuals responsible for carrying out any part of the research misconduct proceeding do not have unresolved personal, professional, or financial conflicts of interest with the respondent. Carleton is responsible for giving the respondent(s) copies of or supervised access to the sequestered research records. Carleton will notify the respondent whether the inquiry found that an investigation is warranted, provide the respondent an opportunity to review and comment on the inquiry report, and attach their comments to the inquiry report. If an investigation is commenced, Carleton will notify the respondent, give written notice of any additional allegations raised against them not previously addressed by the inquiry report, and allow the respondent(s) an opportunity to review the witness transcripts. Carleton will give the respondent(s) an opportunity to read and comment on the draft investigation report and any information or allegations added to the institutional record. Carleton will give due consideration to admissible, credible evidence of honest error or difference of opinion presented by the respondent.

Carleton will bear the burden of proof, by a preponderance of the evidence, for making a finding of research misconduct. Carleton will make all reasonable, practical efforts, if requested and as appropriate, to protect or restore the reputation of respondents against whom no finding of research misconduct is made.

Carleton’s Responsibilities to Committee Members

Carleton will ensure that a committee, consortium, or person acting on the institution’s behalf conducts research misconduct proceedings in compliance with the PHS regulation. Carleton will take all reasonable and practical steps to protect the positions and reputations of good-faith committee members and to protect these individuals from retaliation.

Carleton’s Responsibilities to the Witness(es)

Carleton will provide confidentiality consistent with 42 CFR Part 93 for all witnesses. The institutions will take precautions to ensure that individuals responsible for carrying out any part of the proceedings do not have unresolved personal, professional, or financial conflicts of interest with the witnesses. The institutions will also take all reasonable and practical steps to protect the positions and reputations of witnesses and to protect these individuals from retaliation.

E. Other Procedures and Special Circumstances

Destruction of or Refusal to Provide Research Records

Destruction of research records documenting the questioned research is evidence of research misconduct if a preponderance of evidence establishes that the respondent intentionally or knowingly destroyed records after being informed of the research misconduct allegations. The respondent’s failure to provide research records documenting the questioned research is evidence of research misconduct if the respondent claims to possess the records but refuses to provide them upon request.

Admission of Research Misconduct

If at any point during the proceedings (including the assessment, inquiry, investigation, or appeal stage) a respondent admits to research misconduct, Carleton will promptly notify ORI.  The respondent will sign a written statement specifying the affected research records and confirming the misconduct was falsification, fabrication, and/or plagiarism; committed intentionally, knowingly, or recklessly; and a significant departure from accepted practices of the relevant research community.  Carleton will not close the case until providing ORI with the respondent’s signed, written admission, and giving ORI a written statement confirming the respondent’s culpability and explaining how Carleton determined that the respondent’s admission fully addresses the scope of the misconduct.

Other Special Circumstances

Carleton will immediately notify ORI if any of the following circumstances arise during the misconduct proceedings.

1. The health or safety of the public is at risk, including an immediate need to protect human or animal subjects.
2. Federal resources or interests are threatened.
3. Research activities should be suspended.
4. There is reasonable indication of possible violations of civil or criminal law.
5. Federal action is required to protect the interests of those involved in the research misconduct proceeding.
6. HHS may need to take appropriate steps to safeguard evidence and protect the rights of those involved.

Last Revised: February 13, 2026

For: Faculty

Last Reviewed: February 13, 2026

Maintained by: Office of the Provost

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