Kathryn Partin, who was Colorado State University (CSU), Fort Collins’s research integrity officer for more than 2 decades, recently took over as head of the federal Office of Research Integrity (ORI) and granted Science her first media interview—in the form of written responses to emailed questions. An edited transcript of that interview is below. Separate reporting revealed that Partin is clashing with some of ORI’s current staff; she declined to comment on those personnel matters through a spokesperson, citing federal privacy laws.
Q: What are the strengths and weaknesses of ORI’s current system and what would you like to accomplish?
A: I have gotten great feedback from the research community, including Research Integrity Officers (RIOs) and Responsible Conduct of Research (RCR) Coordinators at institutions, Vice Presidents for Research, research advocacy professional organizations, and journal editors. With regard to misconduct investigations, I have heard that the community is very pleased with the ORI staff’s accessible approach to working with institutions. I have also heard that the community is hungry for more metrics and data about research misconduct trends. They would like us to close cases faster, and would like additional guidance on some technical issues related to their investigations of allegations of research misconduct. Of course, our work needs to be comprehensive but also efficient. The community is concerned about when and how they should approach retractions of research publications. We are still analyzing what we’ve heard before reaching any conclusions about how to address these important issues.
Q: What would it mean for ORI to operate more like the National Science Foundation (NSF)? Would ORI's operations move to the Department of Health and Human Services’s (HHS’s) Office of Inspector General (OIG)? Would misconduct findings no longer be made public?
A: The goal is not for ORI to become more like NSF[’s] OIG, but rather, to allow both organizations to benefit from sharing information about processes and procedures. ORI and NSF are governed by different regulations and oversee different types of research. ORI investigators are scientists, who come to the job with a passion for the power and impact of good biomedical research, and a fierce commitment to ensuring its integrity. NSF placed its investigative scientists in its OIG, which, by definition, has a law enforcement, as well as an oversight role that influences its internal procedures. In addition to its oversight role, ORI has the unique goal of promoting research integrity through its education and outreach activities. Thus, we have interesting similarities and differences.
Q: Would you like to restore ORI's authority to conduct its own investigations (instead of relying on institutions' investigations)? Would you like ORI to be able to subpoena documents?
A: Under ORI’s regulations, ORI is authorized to conduct an allegation assessment, to perform an oversight review of institutions’ investigations, and to request additional information to carry out its review. I want to be sure that institutions make as many findings of misconduct as are warranted, and that ORI concurs as frequently as is appropriate. We are focused on examining all of our processes, and all of the ways we can support institutions in their investigations. Using the best, state-of-the-art training possible, we will be ready to undertake a systematic assessment of our processes, and how we support institutions. Let’s see where that takes us.
Q: ORI often considers plagiarism cases to be authorship disputes and refers these cases to institutions to handle, By contrast, NSF's scientific misconduct findings largely involve plagiarism. Would you like ORI to pursue more plagiarism cases, and if so, why?
A: That is a great question! Innovative science is collaborative, and ORI should not and would not want to undermine that collaborative spirit. In response to your question, not all plagiarism cases involve authorship disputes. Authorship disputes frequently arise from collaborations that are often poorly managed. Providing strong RCR education on authorship and collaborations is essential. However, I do believe that the ORI 1994 Policy on Plagiarism deserves a fresh look, and comments from the research community echo that. To be clear, ORI does pursue plagiarism cases, but those cases do not involve a large part of our findings. In the past five years ORI has made fewer than 10 findings of misconduct involving plagiarism.
Q: Scott Moore has moved over from NSF to serve as ORI acting deputy director. Is he there to help with the transition to a more NSF-like structure?
A: No, not at all! We thought that having Dr. Scott Moore detailed to ORI from NSF would allow us to learn more about NSF[’s] OIG, and allow them to learn more about ORI. Scott is both a JD and a PhD chemist, with robust law enforcement and digital evidence experience. He has been a great asset to ORI, and is making important contributions as Acting Deputy Director. We are currently performing a national search to fill this position after Dr. Moore’s detail is completed.
Q: Do you share the concern from Senator Chuck Grassley (R–IA) and others that HHS sanctions for scientific misconduct are too light? Would you like ORI to have the authority to revoke grant funding? Do you think ORI should refer more cases to the Department of Justice (DOJ) for possible criminal sanctions?
A: ORI has, and will, continue to refer cases to DOJ and OIG that meet the referral standard spelled out in our regulations. Under our regulations, if ORI believes that a criminal or civil fraud violation may have occurred, we must promptly refer the matter to [DOJ], the HHS [OIG] or other appropriate investigative bodies. ORI may provide assistance to the DOJ, OIG, PHS [Public Health Service] offices or other federal offices, as well as state and local offices involved in investigating or otherwise pursuing research misconduct allegations or related matters. DOJ and HHS[’s] OIG share our passion for ensuring the integrity of biomedical research, and we are committed to working together on cases that might merit civil or criminal enforcement.
I believe that our current model of very aggressive notification to the public, journals and funding offices of our findings of research misconduct has merit. In addition, HHS has authority to suspend or terminate a PHS grant, contract, or cooperative agreement as an administrative action under 42 C.F.R. 93.407(a)(4). The funding agency (not ORI) works directly with the institution that received the funding to return PHS funds to that agency. There are policies and procedures in place both at the agencies and at the research institutions to perform such actions, but they are beyond the direct purview of ORI.
Q: Would you like to revisit the federal definition of scientific misconduct and consider bringing back the "serious deviations" clause?
A: Great point! Interestingly, in a preliminary analysis, we have found that >50% of institutional research misconduct policies have an “expanded” definition of research misconduct compared with the Federal-wide definition, which was incorporated in ORI’s current research misconduct regulations in 2005, (falsification, fabrication or plagiarism), and in many cases, the “expansion” includes the older phrase from ORI’s previous regulation, “other practices that seriously deviate from those that are commonly accepted within the scientific community.” A serious deviation is a specific act, other than fabrication, falsification or plagiarism (FFP), which might rise to the level of research misconduct. Institutions that include this term have found that the failure to provide adequate mentorship, for example, or the failure to implement an appropriate data management plan, can be considered a serious deviation that rises to the level of research misconduct. That is an important teaching point I hope to discuss with the research community in upcoming conferences and meetings. My experience at CSU made me wary of this “catch-all” term, because it was nearly impossible to get a committee to agree on both how “serious” an act is and how much it “deviates” from accepted practice. I don’t know that we want to head in that direction, but I am always interested in hearing the argument. The previous term “serious deviation” should not be confused with the language in our current regulations that specifies that for a finding of research misconduct, the FFP act must constitute a “significant departure from accepted practices of the relevant research community”. As explained in the Federal-wide research misconduct policy, this phrase is meant to convey “that behavior alleged to involve research misconduct should be assessed in the context of community practices, meaning practices that are generally understood by the community but that may not be in written form.” Office of Science and Technology Policy Federal [Research Misconduct] Policy, 65 Fed. Reg. 76260, 76261 (2000). For example, the extent to which a micrographic image is manipulated in Photoshop might be deemed “normal” and not misconduct, or might be deemed “a significant departure” and therefore misconduct.
Q: If you wanted to change ORI’s structure or give it more authority, how would this be done? Would it require action by Congress, or a formal rulemaking process?
A: I haven’t made any decision yet about the need for such changes. As we have seen with other current proposed changes promulgated by various arms of the federal government, rulemaking is a long and difficult process. In the short term, there is much we can do without going that route. However, if it subsequently becomes clear that ensuring integrity in PHS-funded research warrants a change in the rules, then the only responsible thing for ORI to do is to initiate that conversation. Whether that would involve a legislative or rulemaking change would, of course, depend on what we were trying to change.
Q: How have your experiences at CSU helped shape your interest in making changes at ORI?
A: My experiences at CSU, conducting NIH-funded, basic neuroscience research, were very positive. It was a great environment to do science and then to become engaged in RCR activities. Since I served both as my institution’s RIO and Director of our RCR program, I learned how strongly those two activities must be coupled to provide the best training environment. I learned that the goal of RCR is to help trainees be successful scientists, with the skills they need to meet important ethical challenges. I learned how devastating findings of research misconduct are—to the individual, the department, and the whole institution. Working in the Research Integrity & Compliance Review Office, I learned how smart, innovative compliance staff can provide outstanding service to faculty and to science, in a collegial, collaborative manner. Most importantly, CSU fed my passion for science, my understanding of the importance of strong, healthy teams, and my commitment to continual improvement of research administration programs.
Q: Do you anticipate pushback from some parts of the community to any proposed changes?
A: I haven’t proposed anything yet! I plan to vet proposed changes thoroughly with the community. Let’s look at the data together, and come up with solutions together. Then, let’s work together to make it happen!