I. Scope
This interim policy applies to all research, research training programs, and research-related activities at George Mason University (“the University”) funded or proposed for funding by the Public Health Service of the U.S. Department of Health and Human Services (PHS), including the National Institutes of Health.
This policy applies to all persons holding any position affiliated with George Mason University (“the University”) and all individuals at the University engaged in teaching, research, or scholarship, or under the control of, or affiliated with, the University to include all (a) full-time and part-time employees of the University; (b) graduate students engaged in research or scholarship activities leading to the generation of reports, conference papers, publications, or creative works in which the University affiliation is indicated; and (c) all undergraduate students who are involved in sponsored research. Persons to whom this policy applies are referred to herein as “University community members.”
II. Policy Statement
Members of the George Mason University community will pursue their research and scholarly activities in a manner that is consistent with the highest standards of ethical, scientific, and scholarly practice. The University will take all reasonable and practical steps to foster an environment that:
(a) promotes the responsible conduct of research, research training, and related activities;
(b) discourages misconduct in research or scholarship (“research misconduct”);
(c) deals promptly with allegations or evidence of possible research misconduct; and
(d) ensures an impartial and unbiased research misconduct proceeding.
The University is also committed to compliance with the requirements for the receipt of Federal funds.
Conduct of Proceedings
All members of the George Mason University community should report observed, suspected, or apparent misconduct in research and scholarship directly to the Research Integrity Officer (RIO).
Research misconduct proceedings for allegations related to PHS-supported research will be managed through the process outlined in this interim policy and its accompanying procedures.
Respondent Non-Participation
If the respondent cannot be located and/or refuses to participate in a proceeding, the proceeding will continue and may still result in a finding of misconduct. Appropriate notifications to funding agencies, publishers, and co-authors will be made to ensure that the research record is corrected, even if a finding of research misconduct is not possible (as described in the associated procedure).
Respondent’s Right to Advisor
Although proceedings are considered an internal personnel matter, the respondent may consult with legal counsel or a non-lawyer personal advisor (who is not a principal or witness in the case) to seek advice and may bring the counsel or personal advisor to interviews or meetings on the case. The counsel or personal advisor may only advise the respondent and does not have a right to interview the complainant, witnesses, committee members, or university officials.
Composition of Committees
The University will select those conducting the inquiry or investigation on the basis of expertise that is pertinent to the matter and, prior to selection, will screen them for any source of potential bias or unresolved personal, professional, or financial conflicts of interest with the respondent, complainant, potential witnesses, or others involved in the matter.
Inquiry and Investigation committees will consist of three to five appointees from among faculty who do not have real or apparent conflicts of interest in the case, are unbiased, and have the necessary expertise to evaluate the evidence and issues related to the allegation. Only university faculty may serve on an inquiry or investigative committee in a research misconduct proceeding. Except in extraordinary circumstances, the majority of the investigation committee’s members will be tenured faculty. Individuals appointed to the committees will typically not have an academic or administrative appointment in the same local unit as the respondent, because people in the same local unit as the respondent(s) may be required to serve as witnesses or expert witnesses in the proceedings. Inquiry committee members may also serve on an investigation committee for the same research misconduct proceeding.
The University may form a standing committee of faculty members trained in research misconduct proceedings that may be drawn upon when new allegations arise. The University may also engage faculty not on this standing committee where additional expertise is warranted.
Research Records
The University will take specific steps to obtain, secure, and maintain the research records and evidence pertinent to the research misconduct proceeding as described in the research misconduct procedures. If an inquiry is warranted, the University will take all reasonable, practical, and lawful steps to obtain custody of all research records and evidence needed to conduct the research misconduct proceeding, inventory those materials, and sequester them in a secure manner. Evidence will be sequestered at or before the notice of inquiry.
The RIO has the authority and obligation to sequester evidence which, in the RIO’s judgment, may be germane to an allegation of misconduct under review.
Timelines and Extensions
These policies and procedures set forth distinct timelines for investigative proceedings regarding allegations of research misconduct. The University shall make every effort to conform to those timelines. However, any failure by the University to meet the timeline requirements set forth herein shall not be grounds for a finding in favor of the respondent.
Procedural deadlines may be extended due to the complexity of cases or in cases of illness or other extenuating circumstances. Requests for such extensions (along with accompanying documentation) will be submitted at least 1 day in advance of the original deadline and must be approved by the Vice President for Research.
Six Year Limitation
These policies and procedures apply only to research misconduct occurring within six years of the date that allegations are received. Exceptions to this limitation include:
- Subsequent use exception. 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. For alleged research misconduct that appears subject to this subsequent use exception, but the University determines is not subject to the exception, the University will document its determination that the subsequent use exception does not apply and will retain this documentation in accordance with the University and sponsoring agency record retention policies.
- Health and safety exception. The six-year time limitation also does not apply if a Federal agency or the University, following consultation with a Federal agency, determines that the alleged research misconduct, if it occurred, would possibly have a substantial adverse effect on the health or safety of the public.
In these circumstances, the RIO, inquiry committee, investigation committee, or Deciding Official may evaluate works that are older than six years.
Need to Know
Disclosure of the identity of respondents, complainants, and witnesses is limited, to the extent possible, to those who need to know, as determined by the University, while conducting the research misconduct proceedings 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. This limitation on disclosure of the identity of respondents, complainants, and witnesses no longer applies once an institution has made a final determination of research misconduct findings.
Confidentiality obligation of all participants
During the course of the proceedings, all individuals involved have an obligation to provide confidentiality to all respondents, complainants, and research subjects identifiable from research records or evidence, except when required to disclose by Federal or state law or regulations, or as specified in this policy. The respondent may disclose this information as needed to defend against an allegation of research misconduct.
University’s right to disseminate information when no finding of misconduct is made
The University reserves the right to communicate general information regarding the results of any proceedings where necessary, in the judgment of the University, to preserve or restore the reputation of the University, the respondent, or the complainant. At no time, however, shall the University reveal detailed personal information regarding the complainant, the respondent, or witnesses. Nor shall the University, at any time, reveal the nature or substance of the evidence or reasoning employed throughout the proceedings.
The University may obtain the advice of non-employees with relevant expertise at any stage of the proceeding, including the preliminary assessment of the allegation.
Administrative Actions
The University reserves the right to take appropriate interim actions at any time during a research misconduct proceeding to protect the integrity of the research process, public health, and any sponsor or institutional funds and equipment involved in the proceeding. The necessary actions will vary according to the circumstances of each case.
Throughout the research misconduct proceeding, the RIO will review the situation to determine if there is any evidence or threat of harm to: research subjects, public health, sponsor or institutional funds and equipment, or the integrity of the externally supported research process. In the event of such a threat, the RIO will, in consultation with other institutional officials and funding agencies, take appropriate interim action to protect against any such threat. Interim actions may include: notifying the Institutional Review Board or Institutional Animal Care and Use Committee to independently conduct an investigation; notifying the Conflict of Interest Committee to independently conduct an investigation; additional monitoring of the research process and the handling of funds and equipment; reassignment of personnel or of the responsibility for the handling of funds and equipment; additional review of research data and results; or delaying publication. The University may also take steps to manage published data or acknowledge that data may be unreliable.
Notifying funding agencies
The RIO shall, at any time during a research misconduct proceeding, notify funding agencies immediately if there is reason to believe that: (a) public health or safety is at risk, including an immediate need to protect human or animal subjects; (b) HHS resources or interests are threatened; (c) research activities should be suspended; (d) there is a reasonable indication of possible violations of civil or criminal law; (e) Federal action is required to protect the interests of those involved in the research misconduct proceeding; (f) the research misconduct proceeding may be made public prematurely and Federal action may be necessary to safeguard evidence and protect the rights of those involved; or (g) the research community or public should be informed.
For research misconduct proceedings that involve Federal support, the University will meet the reporting requirements of the funding agency and will cooperate fully with Federal agencies during any oversight reviews and during the process under which the respondent may contest the agency’s findings of research misconduct and proposed administrative actions. The University will assist the appropriate Federal agency, as needed, to carry out any administrative actions that may be imposed as a result of a final finding of research misconduct by that agency.
For proceedings that involve support from non-Federal entities, the University will comply with all reporting requirements of, and provide information requested by, the funding entity subject to any legal limitations on the disclosure of that information.
Protecting and restoring reputations
Respondents. If a respondent is not found to have engaged in research misconduct, the University will undertake all reasonable, practical, and appropriate efforts to protect and restore the respondent’s reputation. The University will obtain the permission of the respondent before taking any such action.
Complainants, witnesses, and committee members. The University will take all reasonable and practical steps to protect the positions and reputations of good faith complainants, witnesses, and committee members and to protect these individuals from retaliation. Retaliation will be reported to the Vice President or the RIO. Further guidance on retaliation is provided in University research misconduct procedures.
III. Definitions
Allegation: means a disclosure of possible research misconduct through any means of communication and brought directly to the attention of the Research Integrity Officer.
Assessment: means a consideration of whether an allegation of research misconduct appears to fall within the definition of research misconduct and is sufficiently credible and specific so that potential evidence of research misconduct may be identified. The assessment only involves the review of readily accessible information relevant to the allegation.
Complainant: means an individual who in good faith makes an allegation of research misconduct.
Conflict of Interest: means the real or apparent interference of one person’s outside interests with the interests of another person where potential bias may occur due to prior or existing personal, professional, or financial relationships (whether positive or negative). This relationship may be with the person or the person’s close relatives.
Day: means calendar day unless otherwise specified. If a deadline falls on a Saturday, Sunday, or university holiday, the deadline will be extended to the next day that is not a Saturday, Sunday, or university holiday.
Deciding Official: means the institutional official who makes final determinations on allegations of research misconduct and any institutional administrative action.
Evidence: means anything offered or obtained during a research misconduct proceeding that tends to prove or disprove the existence of an alleged fact. Evidence includes documents, whether in hard copy or electronic form, information, tangible items, and testimony.
Fabrication: means making up data or results and recording or reporting them.
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.
Good faith: as applied to
(a) a complainant or witness, means having a reasonable belief in the truth of one’s allegation or testimony based on the information known to the complainant or witness at the time. An allegation or cooperation with a research misconduct proceeding is not in good faith if made with knowledge of or reckless disregard for information that would negate the allegation or testimony.
(b) a university community member or committee member, means cooperating with the research misconduct proceeding by impartially carrying out the duties assigned for the purpose of helping the University meet its responsibilities under this policy. A University community member or committee member does not act in good faith if their acts or omissions during the research misconduct proceedings are dishonest or influenced by personal, professional, or financial conflicts of interest with those involved in the research misconduct proceeding.
Inquiry: means preliminary information-gathering and preliminary fact-finding. An inquiry leads to a determination of whether the allegation has substance and if an investigation is warranted.
Intentionally: means to act with the aim of carrying out the act.
Institutional record: comprises:
(a) The records that the University compiled or generated during the research misconduct proceeding, except records the institution did not consider or rely on. These records include but are not limited to (1) documentation of the assessment; (2) if an inquiry is conducted, the inquiry report and all records (other than drafts of the report) considered or relied on during the inquiry, including, but not limited to, research records and the transcripts of any transcribed interviews conducted during the inquiry, information the respondent provided to the University, and the documentation of any decision not to investigate;(3) if an investigation is conducted, the investigation report and all records (other than drafts of the report) considered or relied on during the investigation, including, but not limited to, research records, the transcripts of each interview conducted, and information the respondent provided to the University;(4) decision(s) by the Deciding Official, such as the written decision from the Deciding Official; (5) the complete record of any institutional appeal;
(b) a single index listing all the research records and evidence that the University compiled during the research misconduct proceeding, except records the University did not consider or rely on; and
(c) a general description of the records that were sequestered but not considered or relied on.
Investigation: means the formal development of a factual record and the examination of that record leading to either a finding of research misconduct or a finding that no research misconduct occurred.
Knowingly: means to act with awareness of the act.
Local unit: means the smallest administrative unit to which an individual is assigned (department, center, or similar).
Notice: means a written or electronic communication served in person or sent by mail or its equivalent to the last known street address, facsimile number, or email address of the addressee.
Person: means any individual, corporation, partnership, institution, association, unit of government, or other legal entity, however organized.
Plagiarism: means the appropriation of another person’s ideas, processes, results, or words without giving appropriate credit. (a) Plagiarism includes the unattributed verbatim or nearly verbatim copying of sentences and paragraphs from another’s work that materially misleads the reader regarding the contributions of the author. It does not include the limited use of identical or nearly identical phrases that describe a commonly used methodology. (b) Plagiarism does not include self-plagiarism or authorship or credit disputes, including disputes among former collaborators who participated jointly in the development or conduct of a research project. Self-plagiarism and authorship disputes do not meet the definition of research misconduct.
Preponderance of the evidence: means proof by evidence that, compared with evidence opposing it, leads to the conclusion that the fact at issue is more likely true than not.
Recklessly: means to propose, perform, or review research, or report research results, with indifference to a known risk of fabrication, falsification, or plagiarism.
Research: means a systematic experiment, study, evaluation, demonstration, or survey designed to develop or contribute to general knowledge (basic research) or specific knowledge (applied research). Research also includes work for the advancement of a discipline or field of study, or the integration of the discipline with other fields, through original research, artistic work, exhibitions, or performance, or by the application of discipline- or field-based knowledge to the practice of the profession.
Research Integrity Officer: or RIO refers to the institutional official responsible for administering the University’s written policies and procedures for addressing allegations of research misconduct.
Research misconduct: means fabrication, falsification, or plagiarism in proposing, performing, or reviewing research or scholarship, or in reporting research results. Research misconduct does not include honest error or differences of opinion.
Research record: means the record of data or results that embody the facts resulting from scientific inquiry. Data or results may be in physical or electronic form. Examples of items, materials, or information that may be considered part of the research record include, but are not limited to, research proposals, raw data, processed data, clinical research records, laboratory records, study records, laboratory notebooks, progress reports, manuscripts, abstracts, theses, records of oral presentations, online content, lab meeting reports, and journal articles.
Respondent: means the individual against whom an allegation of research misconduct is directed or who is the subject of a research misconduct proceeding.
Retaliation: means an adverse action taken against a complainant, witness, or committee member by an institution or one of its members in response to: (a) a good faith allegation of research misconduct; or (b) good faith cooperation with a research misconduct proceeding.
IV. Responsibilities:
Deciding Official
The Deciding Official (DO) makes the final determination of research misconduct findings. The DO cannot serve as the RIO. The DO documents their determination in a written decision that includes whether research misconduct occurred, and if so, what kind and who committed it, and a description of the relevant actions the University has taken or will take. The DO’s written decision becomes part of the institutional record.
The Provost is the Deciding Official. If a particular proceeding presents the Vice President, RIO, Dean, or Director with a real or apparent conflict of interest, the Provost will appoint a replacement to carry out the responsibilities of the individual with a conflict of interest for that proceeding. If the respondent and the Vice President or the Dean or Director disagree as to whether a conflict exists, the Provost will resolve the disagreement.
In cases where conflicts exist or the University has inadequate institutional expertise, the Deciding Official may engage consultants to carry out portions of this policy.
If the Provost has a conflict of interest with a proceeding, the President will serve in all capacities assigned to the Deciding Official under this policy.
Vice President for Research, Innovation, and Economic Impact
The Vice President is responsible for the overall administration of all research related policies. The Vice President will appoint the investigative committee and recommend administrative actions where appropriate.
Research Integrity Officer
The RIO has primary responsibility for the implementation of this policy and associated procedures. The RIO will consult confidentially with persons uncertain about whether to submit an allegation of research misconduct and provide confidentiality to those involved in the research misconduct proceedings. The RIO is the primary point of contact for questions from respondents, complainants, and witnesses about procedural issues. The RIO will receive allegations of research misconduct, conduct the assessment, appoint the inquiry committee, and prepare the inquiry report along with other communication to the respondent, complainant, witnesses, funding agencies, and university officials including the Deciding Official. The RIO has the authority and responsibility to investigate instances of possible bad faith on the part of a complainant, witness, or committee member and to provide evidence of possible bad faith to the Deciding Official. Additionally, the RIO will provide support throughout the investigation and resolution of the allegation.
Deans and Directors
Deans and Directors are responsible for forwarding allegations of research misconduct to the RIO. They are also responsible for providing support for this policy and participating in the associated procedures. For a respondent who does not report to a Dean or Director, those terms mean the respondent’s equivalent senior supervisor. For respondents with multiple reporting lines, all supervisors may be engaged in the process, or one responsible supervisor may be designated by mutual agreement of all supervisors.
Faculty, staff, and students
University community members are responsible for conducting research in an ethical manner, reporting good faith suspicions of research misconduct, cooperating with research misconduct proceedings, and providing information during an inquiry and investigation.
V. Timetable for Review
This policy, and any related procedures, shall be reviewed every three years.
VI. Amendments
Amendments to this policy shall be approved by the SVP and COO and the Provost and Executive Vice President.
VII. Dates
The policy will be effective on January 1, 2026 and will expire upon the next approved revision of University Policy 4007.
VIII. Signatures
Approved:
__/s_______________
Julie Zobel
Senior Vice President & Chief Operating Officer
Approved:
___/s_______________
James Antony
Provost and Executive Vice President
Policy approved: December 17, 2025
Page created: December 17, 2025