The Tri-council Framework On Responsible Conduct In ResearchA Panel Member And Researcher’s Perspective

Marc F. Joanisse, Ph.D.U. Western Ontario

Karen WallaceSecretariat on Responsible Conduct of Research

• Governance of Responsible Conduct of Research in Canada

• Highlights of the Tri-Agency Framework: Responsible Conduct of Research

• Responsibilities of researchers, institutions and Agencies in the Responsible Conduct of Research (RCR)

Overview

Governance of RCR in Canada

• Based on policy, not regulatory authority; enforced through funding

• Institutions are eligible to receive and administer Agency funding on condition that they comply with and enforce Agency policies

• Researchers must follow Agency policies as a condition of funding (set out in application/funding agreement)

Governance Structure

Panel on Responsible Conduct of Research (PRCR)

Secretariat on Responsible Conduct of Research (SRCR)

Volunteer, independent body

Members appointed by Agency Presidents

drawn from a range of disciplines and professional backgrounds, including institutional administrators

experienced in addressing research integrity issues

Advises the three Agency Presidents

Panel on Responsible Conduct of Research (PRCR)

PRCR mandate Review institutional inquiry/investigation reports with all

identifying information removed

Recommend recourse to Agency Presidents for final decision

Promote responsible conduct through education

Provide advice to Agencies on responsibility matters

Review Framework every five years

Recommend revisions to Framework

Secretariat on Responsible Conduct of Research (SRCR)

Formerly Secretariat on Research Ethics

Responsible for human research ethics and responsible conduct of research on behalf of the Agencies

Central point of contact for all matters related to RCR for all three federal research Agencies

CIHR, NSERC, SSHRC

Scope of the Framework

• Applies to researchers holding Tri-Council funds

• And to institutions eligible to administer those funds

Establish and enforce Responsible Research policy

Framework applies to all research conducted under the auspices or jurisdiction of the institution – regardless of source of funding

So – institutions must address all allegations in accordance with the minimum requirements of the Framework

Through initial inquiry

And, if necessary, formal investigation

Report to Agencies if Agency funding is involved

Institutional Responsibilities

Adapting institutional policies to comply with Framework

• June 2012 deadline – extended to end of 2012

Adding external members to investigation committees

• Cost; inconvenience; difficult to identify members

Adherence to timelines

• 2 months for inquiries; additional 5 months for investigations

Education

• Limited resources (human and material)

Framework Implementation: Institutional Challenges

Assistance from the Agencies Advice from Secretariat

• Interpretations of the Framework• Informal discussions re: investigations

Educational resources (free)

• Basic RCR webinars • Interactive on-line RCR tutorial (winter

2014 launch)

• Promote research integrity

• Manage Agency funds responsibly

• Comply with Agency policies

• Provide true and accurate information to the Agencies

Researcher Responsibilities

Breaches Include

• Fabrication, Falsification• Destruction of research records• Plagiarism, Redundant publication• Invalid authorship, Inadequate

acknowledgment• Failure to manage conflicts of interest

• Misrepresentation of data– E.g., falsification in grant applications,

progress reports• Mismanagement/misuse of funds• Non-compliance of Agency policies

– E.g., human ethics, animal care

And…

• Typically directed to the Respondent’s institution

• But could also be directed to Secretariat• Either way, Institution performs the inquiry

Allegations of Misconduct

1. Institutional Investigation– An initial inquiry determines if an investigation

is warranted– Investigation examines validity of allegation– Arm’s length committee investigates, reports

findings to Secretariat

How Are Allegations of Breaches Handled?

2. Institution reports outcome to Secretariat– In a timely manner (see policies)– Report is only required if Agency funds are

involved

3. PRCR meets to discuss outcome of institution report– Anonymized/redacted– Recommends recourse to the relevant Tri-Council

President(s)

Allegations cont.

• Institution-level recourse is independent of PRCR decision/recourse.

• PRCR decision focuses on use of Agency funds– Research not falling under Tri-Council funding

is outside its scope

Scope of Decisions/Recourse

• Letter of concern• Funding ineligibility for a defined period• Terminate/seek refund of funds already paid• Ineligibility to serve on agency committees• Request researcher correct research record• Other recourse possible by law

Potential Agency Recourse

• Launch an independent investigation– Always the Institution’s responsibility

• Recommend institution-level recourse– Recourse is only what can be implemented at the

Tri-Council level– Institutions can provide own recourse if warranted

• Respond to allegations concerning activities not funded through Tri-council

What the Panel Can’t Do

• A postdoctoral fellow applies for NSERC funding, listing a publication as “in press” that is in fact not accepted for publication.

• A peer reviewer notices that this publications doesn’t appear to exist.

• Is this a problem? How big?

Case Study #1

• Yes – it’s a breach of policy. • At time of application the individual

accepts to comply with the Framework.– Even “small” embellishments represent a

significant breach• Sample recourse: Applicant is declared

ineligible to hold funding for 2 years.

Case Study #1 (cont.)

• Following publication of a study in a journal, a PI discovers some of the reported data was likely falsified by a lab member.

• PI fails to report the breach to the Institution in a timely manner.

• Institution discovers the breach when they read about it in Retraction Watch website.

Case Study #2

• Both the PI and lab member are potential respondents in an investigation– PI appears to have known about the breach

and fail to report it.• Institution recommends recourse for both,

individuals– But must also communicate findings with

Secretariat since study was Tri-Council funded

Case Study #2 Cont.

• Lab member is deemed ineligible to hold Tri-Council funds or sit on an Agency peer review panel for life

• PI is deemed ineligible for 2 years• Institution must repay remaining portion of

the award

Case Study 2: Recourse

Questions?

SECRETARIAT ON RESPONSIBLE

CONDUCT OF RESEARCH

Tel.: 613 996-0072

secretariat@rcr.ethics.gc.ca• www.rcr.ethics.gc.ca