The document presents the results of a joint survey conducted by the Council on Governmental Relations (COGR) and the Association of Research Integrity Officers (ARIO) between October and November 2024. The survey targeted research integrity officials at institutions responsible for implementing the revised Public Health Service (PHS) Policies on Research Misconduct, following the publication of a substantially modified Final Rule by the Office of Research Integrity (ORI) in September 2024. Out of 177 responding institutions (primarily public colleges and universities), the majority of survey participants held research integrity leadership roles and had several years of experience managing misconduct cases.
Key findings indicate significant demand for further clarification or guidance on many of the Final Rule’s provisions. Over half of respondents sought additional explanation of several newly defined terms, particularly those related to accepted research practices, the definition of "recklessly," and specifications for institutional records. Most institutional policy changes introduced by the Final Rule were also flagged as needing guidance, with particular attention to handling multi-institutional cases, fostering research integrity, record sequestration, admissions of misconduct, and application of confidentiality principles. The assessment phase, and the requirements to pursue investigative leads and to structure institutional records, emerged as areas of notable uncertainty. Most institutions indicated they would not implement the Final Rule before its official effective date of January 1, 2026.
Written survey comments highlighted practical concerns such as witness protection, administrative burdens, timeline management, handling complex or legacy cases, and harmonization with other federal agency requirements. The survey suggests a broad consensus among research integrity professionals regarding both the need for ORI and community-driven guidance on the new regulations and the areas where clarity is most urgently required. COGR and ARIO plan to use the survey outcomes to inform their engagement with ORI and support institutions navigating the new regulatory landscape.
