AAMC Comments on Proposed Revisions
to PHS Research Misconduct Policies
June 18, 2004 - The AAMC, along with the Association of
American Universities (AAU), the Council on Governmental Relations
(COGR), and the National Association of State Universities and Land-Grant
Colleges (NASULGC) sent a June 15 comment letter
to Office of Research Integrity (ORI) Director Chris Pascal on the
proposed revisions to the Public Health Service Policies on Research
Misconduct. In the letter, the four organizations strongly endorse
the proposed changes to the definition of "research misconduct"
and the incorporation of standard elements that must be present
in order to determine that research misconduct has occurred. "These
key components provide the critical foundation for a common and
systematic approach to addressing allegations of research misconduct,
and bring the proposed regulations into conformity with the Federal
Policy on Research Misconduct issued by the Office of Science and
Technology Policy (OSTP)." However, the groups indicate two
principal problems with the regulations as proposed: a question
of scope or applicability and the evidentiary standards related
to the burden of proof. The letter outlines additional concerns
of the four groups related to confidentiality, coordination with
other agencies, the definitions of allegation and research record,
general responsibilities for compliance, institutional investigations,
completing the research misconduct process, and ORI allegation assessment.
Information:
Susan Ehringhaus, Associate General Council
AAMC Division of Biomedical and Health Sciences Research
sehringhaus@aamc.org
(202) 282-0543
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