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  1. When a research integrity officer (RIO) receives an allegation of curbstoning in PHS-supported research (either from the director of the survey research organization or from a whistleblower), the RIO will assure the questioned data are preserved and held by the RIO pending review of the Allegation.
  2. The RIO will conduct an initial Assessment of the allegation and, in so doing, will specifically address the following:
    1. Does the activity in which the alleged misconduct occurred constitute research as defined by federal regulation, e.g. 42 CFR 93: “systematic experiment, study, evaluation, demonstration or survey designed to develop or contribute to general knowledge  (basic research) or specific knowledge (applied research) relating broadly to public health by establishing, discovering, developing, elucidating or confirming information about, or the underlying mechanism relating to, biological causes, functions or effects, diseases, treatments, or related matters to be studied”?
    2. Could the alleged misconduct have a material impact on the research?  In this context, material impact is defined as follows: If in a single study, a single interviewer or a group of colluding interviewers allegedly falsify either more than 50 interviews (i.e., with positive verification that they were falsified) or more than 2% of the cases that would have been used in analysis if the falsified records were not removed or repaired, then the alleged event is judged to have a potentially material impact on the research and will therefore exceed the de minimus threshold; and
    3. Would the employee responsible for the alleged fabrication or falsification (the Respondent) reasonably be considered a key project personnel as described in the NIH Guide or an Investigator in the PHS regulations 42 CFR 50 subpart F, Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought?

    If the answer to question a. is “no,” the assessment is over; the allegation does not belong in the research misconduct process. 

    If the answers to questions b. and c. above are both “no”, then the fabrication and falsification (curbstoning) would fall below a de minimus threshold and would not be reportable to ORI. (ORI established a similar de minimus standard with respect to allegations of plagiarism; see the ORI Newsletter, Vol. 3, No. 1, p. 3, December 1994.)

  3. The RIO would agree to confer informally with ORI during the Assessment of “borderline” cases.
  4. If the RIO reasonably determines that the answer to either question b. or question c. is “yes,” then the allegation would be handled under the institution’s research misconduct procedures, as would any other allegation of research misconduct.
  5. In cases where the RIO determines that an allegation of fabrication or falsification of data by survey research interviewers falls below the de minumus level described above, the institution would delegate to the SRO review of the allegation and restoration of the integrity of the research record.  Appropriate sanctions would be imposed on the Respondent, as provided by institutional employment policy.

    For the policy to be implemented locally, institutions would have to agree to develop new policy under #5 above, which would allow minor or de minimus allegations of curbstoning to be handled outside of an institution’s research misconduct policy and process.  Basic elements of such a policy include the following:  a policy and process for the survey research organizations informing the RIO of the existence of allegations; a process for protecting the questioned data and providing it to the RIO for safekeeping; a process to safeguard the rights of the Respondent; and a process for restoring the integrity of the research record.

Proposed by a Working Group of Institutional Research Integrity Officers

and endorsed by the SRO Community, 2005

Approved for posting by AAPOR Council, May 13, 2009