D. University Policy for Reviewing Allegations of Research Misconduct

Revised December 8, 2025

I. Introduction

Georgetown University (“Georgetown”) is committed to upholding the highest standards for ethical research and fostering an environment that promotes research integrity and the responsible conduct of research.

Misconduct in research represents a breach of the policies of Georgetown, the standards established by our sponsors, and the expectations of the public and scholarly communities regarding the accuracy, validity, and integrity of Georgetown research.

As a recipient of federal research and development funds, Georgetown must have institutional policies and procedures in place to address allegations of research misconduct. Georgetown has established this Policy and related procedures for review of such allegations, and makes them available to its research community.

Georgetown reviews, and, if necessary, investigates and resolves promptly and fairly all instances of alleged research misconduct, and complies with sponsor requirements for reporting cases of possible research misconduct when sponsored project funds are involved. The review of allegations of research misconduct under this Policy shall be conducted in accordance with 42 CFR Part 93, the Public Health Service (“PHS”) Policies on Research Misconduct (the “PHS regulations”).

II. Scope and Applicability

This Policy applies to all members of Georgetown’s research community and to all campuses and subdivisions of Georgetown University. This Policy applies to all research conducted under the auspices of Georgetown, regardless of funding source.

This Policy applies only to alleged research misconduct occurring within six years of the date of receipt of an allegation of research misconduct, subject to the following exceptions:

  1. 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 limitation through the use of, republication of, or citation to the portions of the research record (e.g., processed data, journal articles, funding proposals, data repositories), alleged to have been fabricated, falsified, or plagiarized for the potential benefit of the respondent.
  2. Exception for the Health or Safety of the Public: The six-year limitation does not apply if Georgetown or a federal regulatory agency determines that the alleged misconduct, if it occurred, would possibly have a substantial adverse effect on the health or safety of the public.

III. Key Definitions and Standards

“Research Misconduct” means (1) fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results.

  • Fabrication is making up data or results and recording or reporting them.
  • Falsification is 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.
  • Plagiarism is the appropriation of another person’s ideas, processes, results, or words without giving appropriate credit. 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.

Research misconduct does not include honest error or differences in opinion, nor does research misconduct include self-plagiarism or authorship or credit disputes.

Issues raised that do not meet the definition of research misconduct but that do involve alleged serious deviation from accepted practices will be referred to other offices or institutional officials with responsibility for resolving the matter, as necessary and appropriate.

A finding of research misconduct requires: (1) a significant departure from commonly accepted practices of the relevant research community; and (2) the research misconduct be committed intentionally, knowingly, or recklessly; and (3) the allegation be proven by a preponderance of evidence.

  • Accepted practices of the relevant research community refer to those practices established by PHS funding components, as well as commonly accepted professional codes or norms within the overarching community of researchers and institutions that apply for and receive PHS awards.
  • Intentionally means to act with the aim of carrying out the act.
  • Knowingly means to act with awareness of the act.
  • Recklessly means to propose, perform, or review research, or report research results, with indifference to a known risk of fabrication, falsification, or plagiarism.
  • Preponderance of 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.

Additional defined terms are included in Georgetown’s Procedures for Reviewing Allegations of Research Misconduct.

IV. General Principles

  1. Obligation to Report Suspected Research Misconduct

    All employees and individuals associated with Georgetown are expected to report observed, suspected, or apparent research misconduct. Georgetown has formal, established mechanisms for reporting alleged research misconduct, including through the Office of Research Oversight and through the University’s anonymous Compliance Helpline. Allegations may also be made to a Georgetown official having responsibility for the implementation of this policy (i.e., the Main Campus Vice Provost for Research, the Medical Center Vice President for Biomedical Research, or the Research Integrity Officer (“RIO”)), or the Research Integrity Committee (“RIC”) Chairperson.

    If an individual is unsure whether a suspected incident falls within the definition of research misconduct, they are encouraged to discuss the matter with their department chair or dean, or other Georgetown official, and/or may contact the RIO or RIC Chairperson to discuss the suspected research misconduct informally. If the circumstances described by the individual do not meet the definition of research misconduct, they may be referred to other offices or officials with responsibility for resolving the matter as necessary and appropriate.
  2. Responsibility to Review Allegations of Research Misconduct

    Georgetown will review allegations of research misconduct in a timely, thorough, competent, objective, and fair manner, as required by applicable regulations, sponsor requirements, and in accordance with this Policy and associated procedures.
  3. Cooperation with Research Misconduct Proceedings

    Individuals covered under this Policy and associated procedures must cooperate with Georgetown officials and applicable regulatory authorities in the review of allegations of research misconduct. Individuals have an obligation to provide relevant information upon request by Georgetown representatives undertaking or supporting review of allegations under this Policy; such information may include research records and materials and electronic communications.
  4. Confidentiality

    Proceedings pursuant to this Policy shall be conducted in such a way as to protect the privacy and confidentiality of complainants, respondents, and witnesses to the extent possible and consistent with conducting a fair and thorough research misconduct proceeding, and as allowed by law. Disclosure of information related to the proceedings will be made only to those who need to know, as determined by Georgetown, in connection with the conduct of a research misconduct proceeding or as required by law. Those who need to know during the course of a proceeding, depending on the facts and circumstances, may include funding agencies, regulatory agencies, institutional review boards, journals, editors, publishers, co-authors, and collaborating institutions.

    Except as provided by this Policy and associated procedures or by law, research misconduct proceedings, and all information generated as part of the proceedings, shall be held in strictest confidence. 
  5. Conflict of Interest

    Georgetown will apply procedures to ensure that individuals responsible for carrying out any part of the research misconduct proceeding do not have unresolved personal, professional, or financial conflicts of interest with complainants, respondents, or witnesses.
  6. Protection of Complainants and Witnesses

    Georgetown will take all reasonable and practical steps to protect from retaliation those individuals who raise allegations or provide information in good faith. The provisions of the Georgetown Whistleblower Protection Policy shall apply to allegations brought in good faith or information provided pursuant to the provisions of this Policy and associated procedures.
  7. Rights and Protection of Respondents

    Georgetown will conduct research misconduct proceedings in a manner that ensures fair treatment to the respondent, including conducting, to the maximum extent practicable, a timely, competent, impartial and unbiased research misconduct proceeding.

    During the course of research misconduct proceedings, a respondent may consult with personal legal counsel or a personal adviser (who is not an individual involved in the case) to seek advice. In any research misconduct proceeding in which a respondent appears before a committee under this Policy, the respondent may have personal legal counsel or a personal advisor present, but the counsel or advisor is not permitted to participate directly with the committee during the proceedings.

    Georgetown will make all reasonable, practical efforts, if requested and as appropriate, to protect or restore the reputation of respondents relative to which allegations of research misconduct are unsubstantiated.

V. Roles and Responsibilities

  1. Complainant: A complainant is the individual bringing forth allegations of research misconduct. The complainant is responsible for making allegations in good faith and cooperating with and maintaining confidentiality relative to research misconduct proceedings.
  2. Deciding Official: The Deciding Official (“DO”) is the institutional official responsible for making the final determination on allegations of research misconduct, including whether research misconduct occurred, by whom, and the actions Georgetown will take in connection with or as a result of research misconduct proceedings. The Provost is the DO for allegations involving main campus research. The Executive Vice President and Dean of the Law Center is the DO for allegations involving Law Center research. The Executive Vice President is the DO for allegations involving Georgetown University Medical Center research.
  3. Respondent: The respondent is the individual against whom allegations of research misconduct have been made or who is the subject of a research misconduct proceeding. The respondent is responsible for cooperating with and maintaining confidentiality relative to research misconduct proceedings. The respondent has an obligation to provide relevant research records and information requested as part of research misconduct proceedings.
  4. Research Integrity Officer (“RIO”): The RIO is the institutional official responsible for administering Georgetown’s written policies and procedures for addressing allegations of research misconduct. The RIO serves as the institutional certifying official, responsible for assuring on behalf of Georgetown that the institution has written policies and procedures for addressing allegations of research misconduct, in compliance with regulatory requirements, and for filing required regulatory assurances and reports. Georgetown’s RIO is the Senior Director of the Office of Research Oversight (“ORO”).
  5. Research Integrity Committee (“RIC”): The Research Integrity Committee is composed of faculty members from across the university. The RIC is responsible for reviewing allegations of research misconduct at the inquiry or investigation stages, in accordance with this Policy, associated procedures, and applicable regulations, and coming to recommended findings for final decision by the DO and, if appropriate, recommended sanctions, relative to the allegations.

    The RIC Chairperson is appointed by the President of the University. Of the other members of the Committee, three shall be appointed by the Executive Vice President of the Medical Center from that campus; three shall be appointed by the University Provost from Main Campus faculty, at least two of whom shall be in the field of natural sciences; two shall be appointed by the Executive Vice President for Law Center Affairs, and three shall be appointed by the Faculty Senate, at least two of whom shall be in the field of natural sciences. Members shall serve a term of three years, and may be reappointed. However, for the first appointments under this Policy, the appointing authorities shall designate their first appointees as having respectively an initial one, two, or where applicable, three-year term, renewable.

    Any member of the Committee whose appointment expires before the case terminates is authorized to continue service until the case is terminated. As need arises (e.g., necessary scientific expertise, a concern with potential conflict of interest), substitute or additional members of the Committee may be appointed to serve in that case on an ad hoc basis by the Committee Chairperson.

VI. Research Misconduct Proceedings

  1. Receipt and Initial Review of Allegations

    Allegations of research misconduct as defined in this Policy may be made by any means of communication (written, oral, or other communication) to a Georgetown official having responsibility for the implementation of this Policy (i.e. the Main Campus Vice Provost for Research, the Medical Center Vice President for Biomedical Research, or the RIO), or the RIC Chairperson. If an allegation is submitted to a Georgetown official or any other institutional member or through any other reporting mechanism, the allegation shall immediately be referred to the RIO.

    The RIO will promptly review allegations, in consultation with the RIC Chairperson and university counsel.

    At any time during any stage of the research misconduct proceedings, Georgetown will notify the appropriate applicable regulatory agency(ies) if: (1) public health or safety is at risk; (2) agency resources or interests are threatened; (3) research activities should be suspended; (4) there is reasonable indication of possible violations of civil or criminal law; or (5) federal action is required to safeguard evidence and/or protect the interests of those involved.
  2. Assessment

    The assessment stage of the proceedings determines whether an allegation meets the definition of research misconduct, falls within the scope and applicability of this Policy and the PHS regulations, and is sufficiently credible and specific so that potential evidence of research misconduct may be identified. If these conditions are met, the matter proceeds to the inquiry stage. If these conditions are not met, the matter is either referred to an appropriate institutional official or office, or closed. The purpose of the assessment is not to determine whether or not research misconduct occurred.
  3. Inquiry

    The inquiry stage of the proceedings involves conducting an initial review of the available evidence to determine whether an allegation warrants an investigation. If the inquiry determines that the allegation meets the definition of research misconduct and that preliminary information-gathering and fact-finding indicates that the allegation may have substance, the matter proceeds to the investigation stage. If these conditions are not met, the matter is either referred to an appropriate institutional official or office, or closed. The purpose of the inquiry is not to determine whether or not research misconduct occurred.
  4. Investigation

    The investigation stage of the proceedings involves conducting a thorough review of available records and information to determine, based on a preponderance of evidence, whether research misconduct occurred (as defined and by the standards outlined in this Policy) and by whom. If research misconduct has occurred, institutional sanctions are determined at this stage by the DO.

VII. Findings and Sanctions

  1. Findings. In accordance with this Policy and associated procedures, Georgetown may make the following findings:
    1. A finding that research misconduct was committed;
    2. A finding that no research misconduct was committed, but that serious error occurred; or
    3. A finding that no misconduct or serious error was committed.

      If the finding is under (iii) above, the case will be closed. Where a case is closed with no findings, nothing related to the research misconduct proceedings may appear in the personnel record of the respondent or the complainant. Any previously imposed sanctions will be promptly lifted.
  2. Sanctions. If the finding is under (i) or (ii) above, or if the respondent concedes the merit of the allegations at any time during the proceedings, the DO, considering the recommendations of the RIC, shall determine the sanction of sanctions to be imposed. These sanctions may include, by way of example:
    1. Letter of reprimand
    2. Relevant training
    3. Special monitoring of future work
    4. Formal notification of sponsoring agencies, funding sources, co-authors, co-investigators, collaborators or journal editors
    5. Publication corrections or retractions
    6. Withdrawal or correction of pending abstracts and papers
    7. Probation
    8. Removal from a particular project
    9. Termination of employment

Sanctions imposed by Georgetown under this Policy are not grievable matters under the University Grievance Code. However, a failure by the University to fully comply with procedures required by this Policy is grievable.

For findings of research misconduct that involve sponsored research, applicable federal agencies and other funding sponsors may impose their own additional sanctions and corrective actions.

Additional procedural details and requirements are included in Georgetown’s Procedures for Reviewing Allegations of Research Misconduct.

VIII. Revocation or Amendment Required by Law

In the event that any changes in state or federal law (including any by state or federal statute, administrative rule or regulation, direction from the a state or federal agency having authority over the subject matter of this Policy, executive order, or controlling judicial order) require the substantive modification or revocation of any provision of this Policy, Georgetown shall make such required changes to the Policy, and the Faculty Senate shall be informed of the revised provisions and the basis for the revisions.

Background to the University Policy for Reviewing Allegations of Research Misconduct

  1. This Policy and the associated Procedures for Reviewing Allegations of Research Misconduct together constitute Georgetown’s “policy” for the purposes of meeting PHS and other federal regulatory research misconduct policy requirements.
  2. Georgetown is responsible for ensuring that its policy and procedures for reviewing allegations of research misconduct meet the requirements of the 42 CFR Part 93 (the Public Health Service (“PHS”) regulations). The policy and procedures will specify where additional requirements specifically apply to PHS-funded research in accordance with these regulations.
  3. Except for matters involving allegations of research misconduct in PHS-supported research, coverage does not extend to Georgetown University students engaged in research. Such students are subject to procedures regarding misconduct declared in the relevant University Bulletins.