It is the general concern of the University that no research done under the jurisdiction of the University expose persons who participate as subjects or respondents to unreasonable risks to their health, general well-being, or privacy.

Specifically, the University is concerned that in all research and related activities involving the use of human subjects: 1) the rights and welfare of the individuals involved are adequately protected; 2) the participation of the subjects is based on freely given, legally effective informed consent; and 3) the risks to the subject are reasonable in relation to the sum of the benefit to the subject and the importance of the knowledge to be gained as to warrant a decision to allow the subject to accept these risks.

Therefore, all research and related activities involving the use of human subjects must be submitted for prior review by the appropriate University Institutional Review Board (IRB) to ensure that the above conditions are met.

Primary responsibility for assuring that the rights and welfare of research subjects are protected continues to rest with principal investigators conducting the research. Others engaged in the conduct of the research share this responsibility. Teachers who assign or supervise research conducted by students have an obligation to consider carefully whether those students are qualified to adequately safeguard the rights and welfare of subjects.

The University has provided the federal government with a formal commitment to ethical and appropriate review and conduct of human subjects research in a document entitled "Federalwide Assurance of Protection for Human Subjects." The detailed University policy and procedures are described in a manual entitled "Investigator's Guide to Human Subjects Research." 

1. Policy. The University of Iowa is committed to maintaining a climate that promotes faithful attention to high ethical standards, that enhances the research process, and that does not inhibit the productivity and creativity of scholars. Instances of research misconduct are inconsistent with such a climate of integrity.

   Research misconduct is contrary to the interests of the University of Iowa, to federal and other funding agencies and sponsors, to the health and safety of the public, to the integrity of research, and to the conservation of funds awarded to the University of Iowa. 

   When committed, research misconduct shatters individual careers, taints the conduct of objective research, undermines the credibility of scholarship, and destroys the confidence among scholars as well as between the University and the public.

   Research misconduct is defined as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. Research misconduct does not include honest error or differences of opinion.

   Findings of research misconduct must meet these criteria: must involve a significant departure from accepted practices of the relevant research community; must be committed intentionally, knowingly, and/or recklessly (see paragraphs d(9), d(11), and d(13) below); and must be proven by a preponderance of the evidence.

   All researchers — faculty, staff, postdoctoral scholars and fellows,and students — must be unfailingly honest in their work, must refrain from deliberate distortion or misrepresentation, and must take regular precautions against the common causes of error. Steps to minimize the possibility of research misconduct include the following:

   1. Researchers must accept responsibility for the quality and integrity of the work reported by them and their collaborators; emphasis must be placed upon the quality and significance of research rather than on quantity and visibility;
   2. Consistent with II-27.10 University of Iowa Authorship Policy, only those who have had a genuine role in the research should be included in authorship of papers, and all named authors should accept responsibility for the quality and integrity of the work reported; and

   3. Researchers must retain research data and records for a period of at least five years following publication to provide verification of the validity of the reported results.

      The likelihood that falsified, fabricated, or plagiarized research will go unquestioned is small. Despite the self-correcting nature of research, instances of research misconduct do occur, and in these cases it is the obligation of faculty, staff, postdoctoral scholars and fellows, and students to report suspected instances of research misconduct to appropriate University officials (e.g., Departmental Executive Officer, Collegiate Associate Dean, Collegiate Dean, Research Integrity Officer, or Vice President for Research). If concerns for research misconduct are not reported directly to the VPR or the RIO, then UI officials who are made aware of research misconduct concerns are required to report them to the RIO.

2. Scope. This policy and the associated procedures apply to:
   1. The planning, conduct, reporting, and review of research, research training, and research-related activities (such as, for example, the operation of tissue and data banks and the dissemination of research information), whether funded or not, and regardless of the source of any funding;
   2. Any person engaged in the above who is employed by or has an official affiliation with The University of Iowa, including any faculty member, staff member, student, postdoctoral scholar, trainee, fellow, visiting scholar, adjunct faculty member, and guest or research collaborator working on campus with University resources; and
   3. Recipient institutions that are required by Reporting Contacts to have institution-wide policies and practices in place that foster the responsible and ethical conduct of research.
3. This policy does not apply to authorship or collaboration disputes. See II-27.10 University of Iowa Authorship Policy.
4. Definitions.
   1. "Allegation" means a disclosure of possible research misconduct made to the University through any means of communication and brought directly to the attention of the VPR or RIO.
   2. "Assessment” means a consideration of whether an allegation of research misconduct appears to fall within the definition of research misconduct; appears to involve creative activities, scholarly work, biomedical or behavioral research, biomedical or behavioral research training, or activities related to that research or research training; 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.
   3. "Complainant" means a person who in good faith makes an allegation of research misconduct.
   4. "Creative activities” may encompass original contributions in the fine, literary, graphic, digital, and performing arts. They may involve creative research-based or research-generating collaborations with libraries, museums, parks, and civic or community organizations (e.g., festivals, symposia, workshops). These activities may include pedagogical projects designed for educational settings on or off campus. They may also include original public-facing work disseminated through relevant venues (e.g., residencies, juried exhibitions).
   5. "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.
   6. "Good faith," as applied to 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.
   7. An "inquiry" consists of preliminary information gathering and preliminary fact finding to determine whether or not an allegation or apparent instance of research misconduct has substance and if an investigation is warranted. An inquiry does not require a full review of the evidence related to the allegation.
   8. Institutional "Deciding Official” (DO) refers to the institutional official who makes final determination on allegations of research misconduct and any institutional actions. The same individual cannot serve as the Institutional Deciding Official and the Research Integrity Officer.
   9. “Intentionally” means to act with the aim of carrying out the act.
   10. "Investigation" means the formal development, examination, and evaluation of a factual research record or record of creative activities or scholarly work. This leads to a finding of whether research misconduct occurred.
   11. "Knowingly” means to act with awareness of the act.
   12. "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 to be true than not.
   13. "Recklessly” means to propose, perform, or review research, or report research results, or creative activities or scholarly works, with indifference to a known risk of fabrication, falsification, or plagiarism.
   14. "Reporting Contact" refers to the office of the funding agency sponsoring the research and/or the oversight agency.
   15. "Research" means a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to general knowledge (basic research) or specific knowledge (applied research) by establishing, discovering, developing, elucidating, or confirming information or underlying mechanisms related to causes, functions, or effects; diseases; treatments; or related matters to be studied.
   16. "Research Integrity Officer (RIO)” refers to the institutional official responsible for administering the institution’s written policies and procedures for addressing allegations of research misconduct.
   17. "Research misconduct" means fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results, or in creative activities or scholarly works.
       1. "Fabrication" is making up data or results and recording or reporting them.
       2. "Falsification" is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research or creative activity or scholarly work is not accurately represented in the research record.
       3. "Plagiarism" is the appropriation of another person's ideas, processes, results, images, or words without giving appropriate credit. It does not include the limited use of identical or nearly identical phrases that describe a commonly used methodology.
   18. "Research record" means the record of data or results that embody the facts resulting from scientific inquiry or the genesis of creative activities or other scholarly works.  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, draft or completed manuscripts or other written materials, abstracts, theses, lab meeting reports, journal articles, images, recordings, records of oral presentations, or online content.
   19. "Respondent" refers to the individual against whom an allegation of research misconduct is directed or who is the subject of a research misconduct proceeding.
   20. "Retaliation." See II-27.8 Anti-Retaliation Policy for Reporting of Misconduct in Research.
   21. "Scholarly work” involves the creation and advancement of knowledge through rigorous inquiry, analysis, and reflection. This work may yield pedagogical materials, peer-reviewed publications, or intellectual property (e.g., patents, trademarks, copyrights). Scholarly work may include original knowledge crafted for or with broad publics, such as podcasts, platforms, maps, or installations. Scholarly work may also include applied research, where multiple stakeholders collaborate to address real-world problems (e.g., policies, protocols, initiatives).
5. Procedures.
   1. Research Integrity Officer. The Vice President for Research (VPR) will appoint an institutional Research Integrity Officer (RIO), who is responsible for the implementation of this policy. The RIO must have the necessary expertise to evaluate the evidence and issues related to the allegation, to interview the parties and the witnesses, and to conduct the initial inquiry.
   2. Reporting allegations to the University. Members of the UI community should report suspected research misconduct to the VPR or the RIO as soon as possible. The VPR and the RIO will both be provided with copies of the allegations. The RIO then determines and notifies the appropriate individuals who have a legitimate need to know about the allegations.
   3. RIO conflict of interest. At each stage of the process, the RIO will carry out their responsibilities without any unresolved personal, professional, or financial conflicts of interest with the complainant, the respondent, or any witness. Within 10 days of receipt of the notice of inquiry, the respondent may object in writing to the RIO's involvement based on a conflict of interest on the part of the RIO. Within 5 days of receipt of the objection, the VPR will determine whether to replace the RIO with a qualified substitute, who will carry out the RIO's responsibilities set forth in this policy.
   4. Confidentiality. To the extent allowed by applicable law, federal regulations, and institutional policies, the confidentiality of the complainant, the respondent, witnesses, and research subjects identifiable from research records or evidence will be protected and disclosure of their identity limited to those who need to know as part of their involvement with the research misconduct proceeding, including the Reporting Contact(s) and any other research sponsor or federal or state agency with a need to know. Inquiries and investigations will be conducted in this manner unless to do so would compromise public health and safety or the effective completion of the inquiry or investigation. Any process prescribed under this policy will be conducted in a manner that ensures fair treatment of the respondent. However, nothing in this section shall limit the remedies available to the institution to correct the scientific record if a finding misconduct is made. For example, the institution may notify journals and co-authors of retraction or other information necessary to correct the scientific record and notify the scientific community without violating this section.
   5. Exigent circumstances requiring immediate reporting. The RIO will notify the appropriate UI officials or Reporting Contact, if applicable, at any stage of the research misconduct process (e.g., assessment, inquiry or investigation) if:
      1. There is an immediate public health or safety risk involved, including an immediate need to protect human or animal subjects.
      2. There is an immediate need to protect sponsoring agency funds, interests, or equipment.
      3. Research activities should be suspended.
      4. There is an immediate need to protect the interests of the person(s) making the allegations or the individual(s) who is/are the subject of the allegations, as well as their co- investigators and associates, if any.
      5. It is probable that the alleged incident is going to be reported publicly, so that the sponsoring agency may take appropriate steps to safeguard evidence and protect the rights of those involved.
      6. The research community or public should be informed (e.g., where the allegation involves a public health-sensitive issue such as a clinical trial).
      7. There is a reasonable indication of possible violation of civil or criminal law. In this instance, the institution must inform the Reporting Contact as soon as is reasonably possible after obtaining that information.
   6. Interim administrative actions and reports. Interim administrative actions will be taken, as appropriate, to protect federal agency funds, safeguard public health, mitigate institutional risk, preserve the integrity of the research misconduct process, and ensure that the purposes of the financial support from funding agencies are carried out.
   7. Burden of proof. The UI has the burden of proving by a preponderance of the evidence that research misconduct has occurred. The burden then shifts to the respondent to prove, by a preponderance of the evidence, any affirmative defense. In determining whether UI has carried the burden of proof imposed by this part, the DO shall give due consideration to admissible, credible evidence of honest error or difference of opinion presented by the respondent. A respondent’s failure to retain and provide research records related to allegations of research misconduct is evidence of research misconduct. The institution must establish by the preponderance of the evidence that the respondent intentionally or knowingly destroyed or withheld research records.
   8. Admission of guilt. If at any point in the research misconduct proceeding, the respondent admits to committing research misconduct the research misconduct proceeding will be paused. A respondent’s admission of research misconduct must be made in writing and signed by the respondent. An admission must specify the falsification, fabrication, and/or plagiarism that occurred and which research records were affected. The admission statement must meet all elements required for a research misconduct finding and must be provided to the Reporting Contact, if applicable, before the institution closes its research misconduct proceeding. The institution must also provide a statement to the Reporting Contact, if applicable, describing how it determined that the scope of the research misconduct was fully addressed by the admission and confirmed the respondent’s culpability.
   9. Honest error and disagreements of scientific, creative, or scholarly opinion. At any point during the research misconduct proceedings, the university may determine that either honest error or disagreement of scientific, creative, or scholarly opinion occurred if the evidence available suggests that the actions reported do not meet definition of research misconduct. If necessary, the university may still require that the research record be corrected.
   10. Allegations potentially involving artificial intelligence. Allegations of research misconduct potentially involving artificial intelligence (AI) will be reviewed and considered with respect to current federal regulations and guidance, federal or external funding agency rules, UI policy and guidance, and the practices of the relevant research community.
   11. Assessment of allegation. Upon receipt of an allegation of research misconduct, the RIO or another designated institutional official must promptly assess the allegation to determine whether the allegation falls within the definition of research misconduct, is within the applicability of this policy or the relevant Reporting Contact, and is sufficiently credible and specific so that potential evidence of research misconduct may be identified. If so, they will determine whether an inquiry is warranted.

   12. Identification of additional respondents. If the RIO identifies additional respondents during any phase of a research misconduct proceeding, the university is not required to conduct a separate inquiry or investigation for each additional respondent. However, each additional respondent must be provided notice of and an opportunity to respond to the allegations, consistent with this policy. Separate inquiry and investigation reports will be written for each respondent, and respondents will only be provided with their own report(s).

       When allegations involve research misconduct at multiple institutions, one institution must be designated as the “lead institution” if a joint research misconduct proceeding is conducted. The RIO will coordinate with the appropriate officials at the other institution(s). By mutual agreement, the institutions will appoint the appropriate inquiry panels and/or investigation committees to review the matter.

   13. Sequestration and notification. On or before notifying the respondent of allegations of research misconduct, the university will promptly take all reasonable and practical steps to obtain all research records and other evidence needed to conduct the research misconduct proceedings. The RIO shall determine what evidence is reasonably needed to conduct a diligent research misconduct proceeding and may consult with subject matter experts (SMEs) in making this determination. The university shall also inventory the research records and other evidence and sequester them in a secure manner. Research records shall be preserved in the formats that they exist at the time of sequester where practical. However, research records may include copies of the data or other evidence so long as those copies are substantially equivalent in evidentiary value as determined by UI Information Technology Services (ITS).
       
       Where the research records or other evidence are located on or encompass scientific instruments shared by multiple users, the institution may obtain copies of the data or other evidence from such instruments, so long as those copies are substantially equivalent in evidentiary value to the instruments. Whenever possible, the institution must obtain the research records or other evidence when additional items become known or relevant to the inquiry or investigation. Where appropriate, an institution must give the respondent copies of, or reasonable, supervised access to the research records that are sequestered in accordance with this policy.
   14. Inquiry. An inquiry’s purpose is to conduct an initial review of the evidence to determine whether an allegation warrants an investigation. An inquiry does not require a full review of the evidence related to the allegation. In addition to reviewing materials sequestered, the RIO may interview relevant witnesses who may have knowledge of facts and evidence pertinent to the allegations.
       1. Inquiry determination. An investigation is warranted if there is a reasonable basis for concluding that the definition of research misconduct, as defined in this policy or by the relevant Reporting Contact, may have substance.  Findings of research misconduct cannot be made at the inquiry stage.
       2. Inquiry report and recommendation. The RIO will produce a written inquiry report that includes all applicable content required by the Reporting Contact or institutional procedures.
       3. Inquiry timeline. The RIO will complete the inquiry and submit the written inquiry report and recommendation to the DO for institutional action within 90 calendar days of initiating the inquiry, unless the DO determines that circumstances clearly warrant a longer period and approves an extension for good cause. In such cases, the inquiry record must include documentation of the reasons for the extension, and the respondent must be notified of the extension.
       4. DO decision and action on the inquiry report. The DO will review the inquiry report and either approve or reject the recommendation of the RIO, stating in writing the reasons for that decision. During this review, the DO may also request additional information to assist in acting on the recommendation of the RIO.The DO will render a decision within 30 calendar days of receiving the inquiry report.
       5. Notice to Reporting Contact. Where the DO approves a recommendation for an investigation in a case involving federal funding, the RIO will notify the Reporting Contact for the relevant federal funding agency on or before the start of the investigation and will provide a copy of the inquiry report and the DO's written decision to the Reporting Contact.
   15. Investigation. The investigation of a research misconduct allegation must be initiated within 30 calendar days of the DO's decision that an investigation is warranted. The RIO shall notify the respondent in writing of the DO’s decision prior to the start of the investigation. The university will take reasonable steps to ensure an impartial and unbiased investigation.
       1. Research Misconduct Committee. The VPR shall appoint a Research Misconduct Committee (RMC) of no less than three faculty members. The committee number can be greater than three and must be an odd number. The RIO will consult with the Associate Provost for Faculty, and the appropriate academic leadership such as the Associate Deans for Faculty and Research for the college of the respondent(s) to identify prospective investigation committee members. The RIO will make every reasonable effort to determine that members of the RMC have no actual or potential personal, professional, or financial conflict of interest relevant to the allegation and that they collectively possess an appropriate level of expertise to competently evaluate the evidence of alleged research misconduct. The DO will review the RIO’s assessment that the members of the RMC have no conflict of interest and have the appropriate expertise to review the allegations of research misconduct. If necessary, the RIO will select investigation committee members external to the UI in order to ensure appropriate subject matter expertise or retain external subject matter experts.  External committee members or subject matter experts will be vetted in a similar fashion as internal, UI committee members.  Subject matter experts are not voting members of the investigation committee. The RIO shall attend committee meetings to assist the committee in its work.
       2. Notice to the respondent of committee composition. The RIO will notify the respondent of the RMC membership prior to the RMC’s first meeting. The respondent will have 5 business days to reply, in writing if they have a reasonable objection to any member of the RMC. If the respondent raises a reasonable objection to a prospective member of the RMC, the RIO will determine whether a conflict, lack of subject expertise, or other circumstance exists such that a prospective committee member’s continued participation in the investigation would be improper or raise a perception of impropriety sufficient to require replacement.
       3. Committee meetings. The RIO will convene the first meeting of the RMC to review the duties and responsibilities, the inquiry report, and the prescribed procedures and standards for the conduct of the investigation. This includes the necessity for confidentiality, for developing a specific investigation plan, and for ensuring a thorough and sufficiently documented investigation. The RMC will make, and the UI will maintain, transcripts or recordings of any witness interviews.  It is within the purview of the RMC to review prior allegations and research integrity concerns, including those that were not brought forward from the inquiry phase. If the evidence raises concerns about new research integrity concerns, those also may be reviewed by the RMC. The RIO will provide written notice of any new allegations.
       4. Use of consultants or content experts. Consultants or content experts may be used at the discretion of the RMC to provide information or specialized content knowledge but should not be present during final committee deliberations and are not members of the committee.
       5. Investigation report. The RMC will prepare a comprehensive written investigation report. If federal funds are involved, the RIO will follow the appropriate Reporting Contact’s requirements for an investigation report. If there are no federal funds involved, the RIO may opt to adopt the requirements outlined by the most relevant Reporting Contact. In the instance of a research misconduct proceeding with multiple respondents, the RMC will issue separate investigation reports and research misconduct determinations for each respondent.
       6. Opportunity for comment. The RMC will provide the respondent a copy of its draft investigation report for comment and rebuttal. The respondent will be allowed 30 days to review and comment on the draft report. The respondent's comments will be attached to the final investigation report. The report will take into consideration the respondent's comments in addition to all other evidence. The RMC may provide factual corrections or consider any new evidence provided in the respondent’s response to the draft investigation report.
       7. Investigation timeline. The RMC’s investigation should be completed within 180 days of the first meeting of the RMC. If the RMC determines that it will not be able to complete the investigation in 180 days, the RIO will notify the DO and submit to the Reporting Contact, if applicable, a written request for an extension that explains the delay, reports on the progress to date, estimates the date of completion of the report, and describes other necessary steps to be taken.
       8. Institutional decision. It is the responsibility of the DO to make a final determination of research misconduct findings. The RMC submits its initial findings to the RIO. The RIO incorporates the RMC’s findings into the investigation report.  The RIO meets with the DO to discuss the report, which includes the respondent’s response to the investigation report. The DO makes the final institutional decision whether to accept the RMC’s findings, reject the RMC’s findings, or send the findings back for the RMC’s further consideration.
          1. If the DO accepts the RMC's findings without substantial modification, the DO's determination, together with the RMC's investigation report, constitutes the final institutional report.
          2. If the DO substantially alters the recommended administrative actions or sanctions, the DO will explain in the decision letter the basis for altering those administrative actions or sanctions. A substantial modification to the RMC’s recommended administrative actions or sanctions is one that changes the outcomes of the RMC’s administrative actions or sanctions. If the DO rejects the RMC’s findings, then the DO’s written explanation must be consistent with this policy and its definition of research misconduct and must be based on the evidence reviewed by the RMC to which the respondent has had an opportunity to respond. The institutional final report will be provided to the appropriate UI officials and the Reporting Contact(s).
          3. The DO has 30 days to render the decision on the RMC’s findings.
       9. Notification. The respondent will be notified in writing at the conclusion of the investigation of its outcome. The respondent will be provided a copy of the institution's final investigation report.
   16. Sanctions and/or administrative actions. If the findings of the investigation or an admission of research misconduct warrant personnel or other administrative actions, the VPR will meet with the appropriate UI leader who has oversight responsibility for the respondent. The VPR will provide the final investigation report to the person with oversight. After reviewing the RMC’s recommended sanctions and/or administrative actions, the person with oversight will determine the appropriate UI leader who is responsible for enacting the administrative actions or sanctions. The VPR will ensure the scientific record is corrected. The university will also ensure that Reporting Contact funds are returned, if applicable.
   17. Appealing sanctions and administrative actions.The final institutional report’s findings are final and are not subject to the UI appeal process. However, the respondent may appeal the sanctions and administrative actions resulting from a finding(s) or admission of research misconduct. Respondents must follow the appropriate UI grievance policy that corresponds to their position at the university. The sanctions and administrative actions will be enacted and enforced prior to and during the UI appeal process.
       1. Grievance Process for Faculty: III-15.3b, III-29, III-29.7
       2. Grievance Procedure for P&S Staff:III-28.4
       3. Grievance Procedure for Merit Staff:III-28.3
       4. Grievance Procedure for Postdoctoral Trainees: Graduate College Postdoctoral Employment Standards
       5. Grievance Process for Graduate Assistants:III-12.4
   18. Notice to Reporting Contact. The UI will comply with any actions required by the Reporting Contact, which may include the obligation to make restitution for the funding or other grant-related actions. The responsible vice president or Executive Vice President and Provost, as applicable, oversees any audits and corrective action that may be required because of the findings of the investigation.
   19. Finding of no research misconduct. If the institutional final report has no finding(s) of research misconduct, the RIO will consult with the respondent and all appropriate UI leadership to undertake all reasonable, practical, and appropriate efforts to restore the respondent's reputation. For faculty, this includes, but may not be limited to, guidance and resources discussed in the “Faculty Support & Guidance” document. Any institutional actions to restore the respondent's reputation must first be approved by the Executive Vice President and Office of the Provost.
   20. Retaliation; reputation of complainant and others. Regardless of whether the institution or the Reporting Contact determines that research misconduct occurred, the RIO will undertake all reasonable and practical efforts during all stages of the research misconduct proceedings to protect complainants who make allegations of research misconduct in good faith, witnesses, committee members, and UI administrators and staff. Those who make allegations of research misconduct with knowing or reckless disregard for the truth will be subject to discipline under applicable UI policies. If an allegation of retaliation is made, the RIO will assess and make a determination if the allegation is in accordance with II-27.8 Anti-Retaliation Policy for Reporting of Misconduct in Research. This assessment is separate from the underlying research misconduct investigation and may require other UI action or notification.
   21. Early termination of inquiry or investigation. If the university terminates an inquiry or investigation for any reason without completing all relevant requirements of the applicable funding agency regulations (other than closing an inquiry because no investigation is warranted or a finding of no misconduct from a completed investigation), the RIO will submit a report to the Reporting Contact, including a justification for the proposed termination.
       
       The RIO will report to the Reporting Contact as required and will keep the Reporting Contact apprised of any developments during the course of the inquiry or investigation that may affect current or potential funding for the individual(s) under investigation. The RIO will also keep the funding agency apprised of any developments to ensure appropriate use of funds and otherwise protect the public interest.
       
       The university will provide full and continuing cooperation with any  funding agency during its oversight review of any alleged research misconduct or any subsequent administrative hearings or appeals resulting from the Reporting Contact review.
   22. Records. All records pertaining to an allegation of research misconduct shall be kept in accordance with the record-keeping requirements of the UI Official Record Retention Schedule and the corresponding Reporting Contact.
   23. This policy shall be reviewed not more than five years following its implementation.

1. Purpose. These guidelines provide information to whistleblowers on an appropriate method of submitting retaliation complaints and subsequent procedures for resolving the complaints.

   These guidelines apply to all instances of possible retaliation against whistleblowers who make allegations of research misconduct covered by the University of Iowa Policy on Ethics in Research (II-27.6).

2. Definitions.
   1. "Adverse action" means any action taken by a member of The University of Iowa which negatively affects the terms or conditions of the whistleblower's status at the University, including but not limited to their employment, academic matriculation, awarding of degree, or University relationship established by grant, contract, or cooperative agreement.
   2. "Allegation" means any disclosure, whether by written or oral statement, or any other communication, to a University, a governmental or other sponsoring agency official who receives the allegation while acting in their official capacity, that the University or member thereof has engaged in research misconduct.
   3. "Deciding official" means the official designated by the President of the University to make a final University determination as to whether retaliation occurred.
   4. "Good faith allegation" means an allegation of research misconduct made with a belief in the truth of the allegation which a reasonable person in the whistleblower's position could hold based upon the facts. An allegation is not in good faith if made with reckless disregard for or willful ignorance of facts that would disprove the allegation.
   5. "Research misconduct" means fabrication, falsification, plagiarism, or other practices that seriously deviate from those that are commonly accepted within the research community for proposing, conducting, or reporting research. It does not include honest error or honest differences in interpretations or judgments of data or creative innovations that are nonetheless ethical, legal and meet professional standards.
   6. "Responsible official" means the official designated by and reporting to the President of the University to establish and implement the University's anti-retaliation policy for reporting of misconduct in research.
   7. "Retaliation" means any adverse action or credible threat of an adverse action taken by the University, or member thereof, in response to a whistleblower's good faith allegation of research misconduct. It does not include the University's decision to investigate a good faith allegation of research misconduct.
   8. "University" means The University of Iowa.
   9. "University member, or member" means a person who is employed by, affiliated with under a contract or agreement, or under the control of the University. University members include but are not limited to faculty, students, administrators, teaching and support staff, researchers, clinicians, technicians, and fellows.
   10. "Whistleblower" means an individual who makes a good faith allegation of research misconduct or demonstrates an intent to make a good faith allegation (or what is perceived to be an allegation) while a member of the University at which the alleged research misconduct occurred.
3. Processing whistleblower retaliation complaints.
   1. Responsible official.
      1. The University has designated the University of Iowa Research Integrity Officer (RIO) the "Responsible Official" to establish and implement the University's Policy for Reporting Misconduct in Research. The Responsible Official also serves as a liaison between the University and the sponsoring agency, and will prepare and submit all reports to the research sponsor.
      2. The Responsible Official shall be free of any real or apparent conflicts of interest in any particular case.
      3. If involvement of the Responsible Official in a particular case creates a real or apparent conflict of interest with the University's obligation to protect good faith whistleblowers, and the conflict cannot be satisfactorily resolved for that case, the Vice President for Research shall appoint a substitute Responsible Official who has no conflict of interest.
   2. Notice of University policy. The University shall provide to all its members notice of its Anti-Retaliation Policy for Reporting of Misconduct in Research. The notice shall include the requirement set forth regarding a whistleblower's deadline for filing a retaliation complaint.
   3. Filing complaints.
      1. A whistleblower who wishes to receive the procedural protections described by these guidelines shall file their retaliation complaint with the Responsible Official within 180 days from the date the whistleblower became aware or should have become aware of the alleged adverse action. The University shall review and resolve all whistleblower retaliation complaints and should do so within 180 days after receipt of the complaint. If the whistleblower fails to receive a University response to the complaint in accordance with these Guidelines within ten working days, the whistleblower may file the retaliation complaint directly with the sponsoring agency.
      2. The retaliation complaint must include a description of the whistleblower's research misconduct allegation and the asserted adverse action, or threat thereof, against the whistleblower, by the University or its members in response to the allegation. If the retaliation complaint is incomplete, the Responsible Official shall describe to the whistleblower what additional information is needed in order to meet the minimum requirements of a complaint under this II-27.8c(3).
   4. Responding to complaints.
      1. Upon receipt of a whistleblower retaliation complaint, the Responsible Official shall notify the whistleblower of receipt within ten working days after receipt. The notice shall also inform the whistleblower of the process the University proposes to follow in resolving the retaliation complaint and the necessary actions by the whistleblower required under that process.
      2. The whistleblower may raise any concerns about the proposed process with the Responsible Official and the University may modify the process in response to the whistleblower's concerns.
      3. The whistleblower has five working days from the date of receipt of the initial notification in II-27.8c(4)(a) to:
         1. accept the proposed process, although the whistleblower may also submit documentation for the official record about any concerns they may have about the proposed process; or
         2. not accept the proposed process. If the whistleblower rejects the proposed process, they may pursue other remedies as provided by law.
      4. The University shall notify the sponsoring agency of any whistleblower retaliation complaint it receives within ten working days after receipt of the complaint.
   5. Interim Protection.
      1. At any time before the merits of a whistleblower retaliation complaint have been fully resolved, the whistleblower may submit a written request to the Responsible Official to take interim actions to protect the whistleblower against an existing adverse action or credible threat of an adverse action by the University or member.
      2. Based on the available evidence, the Responsible Official shall make a determination of whether to provide interim protections and shall advise the whistleblower of their decision in writing. Documentation underlying the decision whether to provide interim protections shall become part of the record of the complaint. When the whistleblower retaliation complaint is fully resolved, any temporary measure taken to protect the whistleblower shall be discontinued or replaced with permanent remedies.
4. Resolution of complaints.
   1. General.
      1. For each whistleblower retaliation complaint received, the University shall adhere to the process for resolving the whistleblower retaliation complaint, or settle the complaint, as described below.
      2. The process should be completed within 180 days of the date the complaint is filed, unless the whistleblower agrees to an extension of time. The University shall promptly report the final outcome of either process or any settlement to the sponsoring agency.
      3. If the whistleblower declines the University's proposed process according to these guidelines, they may pursue any other legal rights available to the whistleblower for resolution of the retaliation complaint. However, sponsors, including the federal government, may deem the University to have met its obligation under federal regulations and may not pursue the whistleblower complaint further.
   2. University investigation.
      1. The University shall conduct an investigation of the whistleblower retaliation complaint according to these Guidelines and implement appropriate administrative remedies consistent with the investigation's finding and University decision thereon.
      2. An investigation of whistleblower retaliation shall be timely, objective, thorough, and competent. The investigation should be conducted by a panel of at least three individuals appointed by the Responsible Official. The members of the investigation panel, who may be from outside the University, shall have no personal or professional relationship or other conflict of interest with the whistleblower or the alleged individual retaliator(s), and shall be qualified to conduct a thorough and competent investigation.
      3. The investigation shall include the collection and examination of all relevant evidence, including interviews with the whistleblower, the alleged retaliator(s), and any other individual who can provide relevant and material information regarding the claimed retaliation.
      4. The University shall fully cooperate with the investigation and use all available administrative means to secure testimony, documents, and other materials relevant to the investigation.
      5. The confidentiality of all participants in the investigation shall be maintained to the maximum extent possible throughout the investigation.
      6. To encourage and protect whistleblowers, it is University policy that no reference to good-faith reporting of University-related misconduct shall be made in personnel files, letters of recommendation, performance appraisals, or any other permanent evaluative documents without the concurrence of the whistleblower.
      7. The panel members shall evaluate and respond objectively to any concerns raised by the whistleblower about the process, including concerns regarding the selection of the Deciding Official, Responsible Official, and specific panel members, which are raised prior to resolution of the complaint.
      8. The conclusions of the investigation shall be documented in a written report and made available to the whistleblower. The report shall include findings of fact, a list of witnesses interviewed, an analysis of the evidence, and a detailed description of the investigative process.
      9. The Vice President for Research shall be the Deciding Official. The Deciding Official shall make a final University determination as to whether retaliation occurred. This decision shall be based on the report, the record of the investigation, and a preponderance of evidence standard. Appeals may be made to the University President and subsequently to the Board of Regents via the usual appeals process.
      10. If there is a determination that retaliation has occurred, the Deciding Official shall determine what remedies are appropriate to satisfy the University's obligation to protect whistleblowers. The Deciding Official shall, in consultation with the whistleblower, take measures to protect or restore the whistleblower's position and reputation, including making any public or private statements, as appropriate. In addition, the Deciding Official may provide protection against further retaliation by monitoring or disciplining the retaliator.
      11. The University shall promptly notify the sponsoring agency of its conclusions and remedies, if any, and forward the underlying investigation report to the sponsor.
      12. The University recognizes that the sponsoring agency may, at its own discretion, review the University report to determine whether the University has substantially followed the process described herein.
      13. University compliance with this process does not bar the whistleblower from seeking redress against the University's decision under state law, University procedure, rules of the Board of Regents, policy, or agreement, or as otherwise provided.
   3. Settlement. In lieu of the option described above, the University and whistleblower may, at any time after the retaliation complaint is made, enter into any binding settlement agreement which finally resolves the retaliation complaint. If both parties agree, the Responsible Official shall facilitate negotiation of such settlements. If such an agreement is reached, the University and the whistleblower shall sign a statement indicating that the retaliation complaint has been resolved. The University shall within 30 days send a copy of the signed statement to the sponsoring agency. The settlement may not restrict the whistleblower from cooperating with any investigation of an allegation of research misconduct.
5. University compliance. At any time a sponsoring agency may review the University's compliance with these guidelines to the extent that the University relies on these guidelines for regulatory compliance. The University and its members shall cooperate with any such review and provide the sponsoring agency access to all relevant records. If the University's procedures and implementation thereof substantially conforms to II-27.8c and II-27.8d above, it shall be deemed to have met its whistleblower protection obligation under federal regulations.

1. It is the policy of the University that all activities involving the use of live vertebrate animals be conducted in accordance with federal law and regulatory guidelines regarding the humane care and use of animals. The University has provided the federal government with a formal commitment to humane and appropriate review and conduct of animal research in a document entitled "University of Iowa Assurance of Compliance with Public Health Service Policy on Humane Care and Use of Laboratory Animals."
2. All research and instruction performed by University of Iowa faculty, staff, and students involving the use of live vertebrate animals must be submitted for prior review and approval to the Institutional Animal Care and Use Committee (IACUC) to ensure that the above conditions are met. This requirement applies irrespective of the funding source or location on or off campus of the research or instruction. In the absence of an IACUC-approved, valid Animal Protocol Form, an investigator may not perform procedures with live vertebrate animals or acquire animal data under the project in question.
3. The Office of Animal Resources is responsible for the procurement and husbandry of all live vertebrate animals at The University of Iowa.
4. It is the responsibility of the principal investigator to assure that all individuals involved in the use of animals in research and instruction be appropriately trained in the procedures to be used in their approved activities. All individuals named in research protocols involving the use of live vertebrate animals must also have completed the University of Iowa training requirement prior to performing animal procedures.
5. Details of the University policy and procedures are available at https://animal.research.uiowa.edu.

1. Purpose and expectations.
   1. Authorship explicitly assigns both credit and responsibility for intellectual work and has tangible implications for faculty, staff, and student participants on project teams. It is the policy of The University of Iowa that authorship assignments thus should honestly reflect actual contributions as a function of the ethical conduct of scholarship. Faculty should be especially aware of their responsibility to safeguard the rights of staff and students at all levels to publish.
   2. Adherence to this policy is specifically intended to eliminate authorship assignment rooted in power inequities, inappropriate practices, and perceptions of conflict of interest in the presentation of scholarly findings.
   3. Participants are expected to engage early in the publication development process in open and clear communication about the assignment of authorship roles with their potential publishing colleagues. Written agreements specifying the details of authorship and contributions may be warranted in many cases but are good practice in all cases.
2. Applicability.
   1. This policy applies to all individuals at The University of Iowa engaged in the publication of research, defined broadly as all forms of scholarly investigation or creative work, regardless of funding source.
   2. Colleges and departments are encouraged to develop additional "best practices" guidelines regarding authorship for their faculty, staff, and students that address discipline-specific issues.
   3. The term "publication" as used in this policy is meant generically, representing as inclusively as possible any manner of report, paper, manuscript, article, book, chapter, treatise, or other publishable product whether printed or digital in format.
3. Attribution of authorship.

   1. Authorship is limited to those who meet both of the following criteria and expectations; all those who meet these standards should be included as an author:

      1. Significant intellectual contribution to a project through conception and design, or data collection and analysis, or interpretation; and
      2. Ability to identify their own contribution, and ideally the contributions of each participating author, and defend the major aspects of the project presented in the publication, although not necessarily all the technical details.

      In addition, it is expected that each author has been given the opportunity to participate in the drafting of the manuscript (or substantive revision of its scholarly content) and approves the final version of the manuscript to be published.

   2. Provision of logistical, financial, or administrative support alone does not constitute a valid basis for authorship. Recognition of these types of contribution is appropriate for an acknowledgements section of a publication.
4. Standards. This policy acknowledges that the significance of a particular method of ordering authorship may be understood in a given setting but that order of authorship has no generally agreed-upon meaning across all academic disciplines. Additionally, standards for "substantive" and "scholarly content" differ among the various disciplines and publishing venues. This policy requires that criteria for attributing and ordering authorship by practitioners of specific disciplines at The University of Iowa will be widely recognized and consistent across that discipline as a whole, and generally consistent with the standards of the publication in which the work appears, including the following.
   1. Authorship roles. As a practical issue for multi-author publications in disciplines where "lead" (also known in some fields as "corresponding") authors are the norm, collaborators on a publication are to agree as early in the planning process as practical on one author as lead. The remaining authors are then designated as participating authors. Lead designation is intended as an administrative role and doesn't necessarily imply greater individual contribution to the publication. In disciplines where authorship practices are typically more consensus based, collaborators are encouraged to proactively discuss responsibility for administrative matters relating to publication submittal.
      1. Lead author. Depending on the discipline and the nature of the collaborative work, the lead author need not be the first, last, or most senior author, nor necessarily the principal investigator or project leader. At the outset of the study all authors should discuss the outline of work and a tentative order of authorship should be established with the logic governing this order made explicit. As projects proceed, agreements regarding authorship may need to be changed. The lead author is responsible for the integrity of the work as a whole, and ensuring that reasonable care and effort has been taken to determine that all the data are complete, accurate, reasonably interpreted, and accessible to others within the norms of the discipline and requirements of the publishing venue. It is the responsibility of the lead author to assure that the contributions of all participating authors are properly recognized. In cases where a lead author has been formally assigned, this individual assumes overall responsibility for the publication and typically serves as the managerial and corresponding author. In consensus situations, all authors jointly share responsibility. The lead author (or consensus authors) is (are) responsible for confirming that all participating authors meet this policy's authorship criteria, for providing the manuscript's final draft to each participating author for review and approval, and for following any journal-specific requirements governing author review and consent (such as signature forms).
      2. Participating author. Each author of a publication, regardless of relative seniority or level of contribution, is responsible for providing confirmation of authorship in accordance with this policy's criteria and the requirements of the selected publication venue. Confirmation of authorship includes verifying review and approval of the final manuscript to be published. Each author is responsible for the content of those portions of the manuscript ascribed to them, including the integrity of any applicable research. An individual offered authorship of a publication for which they do not satisfy the criteria for authorship as set forth in this policy should decline authorship in accordance with this policy and University policies regarding responsibilities to scholarship (see III-15.3). All reasonable attempts will be made to seek confirmation in accordance with this policy from individuals who meet authorship criteria but have left the institution (e.g., students who have graduated) or are no longer in contact with the lead or other participating authors.
   2. Appropriate use of acknowledgements and disclosures. The nature and character of acknowledgements appearing in manuscripts varies considerably depending on a given discipline. The following principles are meant to provide guidance but not contradict the requirements prescribed by specific journals or publications.
      1. "Acknowledgements" should communicate to granting agencies, promotion committees, scholarly readers, and others the specific contributions that are insufficient under this policy to justify authorship. Such contributions include general supervision of a research group, assistance in obtaining funding, technical support, and assistance in writing and editing the manuscript. Individuals who may have participated in the development of a publication but who do not meet the criteria for authorship, such as editorial assistants, illustrators, medical writers, or other individuals, provide a valuable contribution to the writing and editing of publications. Since those contributions do not meet the criteria for authorship under this policy, these individuals should be listed in an acknowledgements section of the published work.
      2. All authors, in their manuscripts submitted for review and publication, must disclose the source(s) of support (financial and/or tangible resources) for the work unless otherwise instructed by the journal or publication. Examples of support include but are not limited to 1) research and educational grants, 2) contracts, 3) corporate sponsorships, 4) gifts, and 5) institutional sources (departmental, collegiate, central administration, or hospital). Authors shall fully disclose all relevant financial interests that could be viewed as a potential conflict of interest in accordance with University policies (see II-18).
      3. Since it is possible that readers may infer endorsement of the data and conclusions from an acknowledgement, those acknowledged should give written permission and a disclaimer shall be included specifically indicating that inclusion in the acknowledgements does not imply endorsement by those named.
5. Violations. The following are examples of acts that may violate this policy:
   1. Intentional exclusion of a person as author who meets the criteria defined above in paragraph c of this policy.
   2. Acceptance or ascription of an honorary authorship. Honorary (guest, courtesy, or prestige) authorship is granting authorship out of appreciation or respect for an individual, or in the belief that the expert standing of the honored person will increase the likelihood of publication, credibility, or status of the work.
   3. Acceptance or ascription of a gift authorship. Gift authorship is credit, offered from a sense of obligation, tribute, or dependence, within the context of an anticipated benefit, to an individual who has not appropriately contributed to the work.
   4. Acceptance or ascription of a ghost authorship. Ghost authorship is the failure to identify as an author someone who made substantial contributions to the research or writing of a manuscript thus meriting authorship or allowing significant editorial control of a publication by an unnamed party, which may constitute a real or perceived conflict of interest that should be disclosed.
6. Dispute resolution and disciplinary action. A person who believes their authorship rights have been intentionally violated or who wishes to report other improper authorship practices as identified above in paragraph e of this policy may pursue informal mediation of the issue through departmental or collegiate channels or a person may bring a formal complaint under this policy to the Research Integrity Officer (RIO) or other designated individual appointed by the Vice President for Research for resolution. In the event that improper authorship practices are identified and depending on the University status, including but not limited to faculty, staff, or student, of the respondent whose action is the subject of the complaint, the RIO or other designated individual may consult with appropriate collegiate or departmental offices in determining appropriate sanctions and whether and when to pursue formal disciplinary action. During dispute resolution the involved authors are expected to refrain from actions that may damage the authorship interests and rights of the other participating authors.

(See also II-18.6 Conflict of Interest in Research.)