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Research Compliance

Research Integrity & Conflicts of Interest

Research Integrity

The Faculty Handbook contains critical information regarding research conduct and expectations of faculty at William & Mary.

Responsible Conduct of Research (RCR) is the National Science Foundation's implementation of Section 7009 of the America COMPETES Act. The intent is to train future generations of scientists to perform their research in an ethical fashion that upholds the highest integrity level. All institutions certify that they implement responsible research conduct training for undergraduates, graduates and Post Doctoral researchers supported by NSF funding at the time of proposal submission. William & Mary employs the CITI training module on Responsible Conduct of Research as a beginning review of RCR. When accessing the CITI modules, we ask that participants list their affiliation as "William & Mary."

Financial Integrity

Commonwealth Financial Conflict of Interest

Though the Commonwealth of Virginia conducts an annual statement of economic interest through the Office of Administration, the management of research conflict of interest requires an additional layer of oversight. Disclosures related to potential conflict of interest are completed at the time a proposal Routing and Review form is submitted to OSP. In the case where a potential conflict of interest exists, the Vice Provost for Research will assist in determining actions necessary to conduct the research while avoiding a full-blown conflict. 

DHHS Financial Conflict of Interest

NSF Research Misconduct Training Requirement

This requirement applies to all personnel supported by NSF grants. 

General Requirements

As a result of the America COMPETES Act, NSF implemented a training requirement for Research Misconduct effective 1/4/10. The requirement is for institutions to develop and implement a Research Misconduct training policy for undergraduates, graduates, post-docs and faculty researchers "supported" by NSF sponsored research.

Please note: "NSFOIG will view support in the same context that supported is used when provided as acknowledgement on a publication. Thus salaries, supplies, materials, etc." per Peggy L. Fischer Associate Inspector General for Investigations, Office of Inspector General, NSF.

This is one of the Certifications and Assurances the Sponsored Research Office endorses every time a NSF proposal is submitted. The awardee institutions "bear primary responsibility for prevention and detection of research misconduct and for the inquiry, investigation, and adjudication of alleged research misconduct."

Defining Misconduct

According to NSF OIG, Research Misconduct is defined as the following:

  1. Research misconduct means fabrication, falsification or plagiarism in proposing or performing research funded by NSF, reviewing research proposals submitted to NSF, or in reporting research results funded by NSF.
    1. Fabrication means making up data or results and recording or reporting them.
    2. Falsification means manipulating research materials, equipment or processes, or changing or omitting data or results such that the research is not accurately represented in the research record.
    3. Plagiarism means the appropriation of another person's ideas, processes, results or words without giving appropriate credit. Plagiarism includes "self-plagiarism."
    4. Research, for purposes of paragraph (a) of this section, includes proposals submitted to NSF in all fields of science, engineering, mathematics, and education and results from such proposals.
  2. Research misconduct does not include honest error or differences of opinion. 

Proposal Requirements

An institution must:

  1. have a training plan established to provide appropriate training and oversight in the responsible and ethical conduct of research; per the Grant Proposal Guide, the university's certification to this is required for each proposal,
  2. training plans are not required to be included in the proposals to NSF, but NSF has advised institutions that the training plans are subject to review upon request,
  3. institutions must designate one or more persons to oversee compliance with the RCR training requirement and
  4. institutions are responsible for the verification process in asserting undergrads, grads, Post-Docs, and PI's supported by NSF have successfully completed training in RCR.

University Action

The university has established an initial plan for the Responsible Conduct in Research training protocol and continues to refine verification processes. All NSF supported undergraduate students, Graduate Students and Post-Docs must take the appropriate training modules provided by CITI. Additionally, advanced training will be required according to discipline as directed by PI or appropriate Department Chair.

Resources on Ethics Education in Science and Engineering