The Council on Governmental Relations (COGR) and the Association of Research Integrity Officers (ARIO) jointly responded to the Office of Research Integrity’s (ORI) request for input on revising the 2005 Public Health Service (PHS) Policies on Research Misconduct. Representing leading U.S. research universities and research integrity professionals, COGR and ARIO emphasized the importance of regulatory clarity, fairness, harmonization across federal agencies, and a balance between thoroughness and administrative efficiency. The organizations urged ORI to provide institutions with more discretion in managing the scope and timeline of investigations, limit mandatory reviews to cases substantiated by evidence, and clarify intent and confidentiality standards within the regulations. They advocated for limiting research misconduct definitions strictly to fabrication, falsification, and plagiarism, cautioning against conflating these with broader scientific integrity or unrelated issues such as foreign ties or harassment, which are better addressed through distinct processes.
Their recommendations included revising or removing the so-called "subsequent use" exception to the six-year limitation, better defining state-of-mind terms necessary for findings of misconduct, and updating confidentiality requirements to reflect contemporary research practices involving multiple institutions and stakeholders. Furthermore, COGR and ARIO proposed replacing rigid investigative timelines and the current administrative appeals process with more flexible, case-specific frameworks aligned with other federal agencies. They also suggested refining the definition of plagiarism and retaining established foundational terms to maintain the effectiveness and focus of the policies. The letter closed with a call for ongoing dialogue, expressing appreciation for ORI’s outreach to stakeholders and reiterating the value of continuous regulatory review to advance research integrity objectives.
