As reported in the Report on Research Compliance, the Office of Inspector General (OIG) of the National Science Foundation (NSF) recently held a workshop on the performance of federal research misconduct investigations.[1] Within OIG, investigations involving research are handled by the Division of Research Integrity and Administrative Investigations in the Office of Investigations.
Research integrity investigations often deal with issues like plagiarism or data fabrication and falsification. These are highly specialized investigations, yet most of the best practices covered in the workshop could apply to any compliance-related investigation.
For example, in one of the sessions—which focused on writing investigative reports—the guidance provided in the workshop focused on the following practices:[2]
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Be very specific when writing up allegations and conclusions.
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Provide timelines and the “backstory” of the allegations.
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Address each element of an allegation or finding.
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Explain any patterns and the impact of each finding.
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Explain how conclusions were reached.
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Carefully determine which supporting documents to include (the readers don’t want or need everything you collected).
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Provide references to supporting documents, including emails, transcripts of interviews, etc.
Every one of these recommendations applies to just about every other compliance-related investigation. Almost every report I wrote in my investigative career possessed these attributes.
After reviewing the presentations from the workshop, I feel more strongly than ever that the vast majority of best practices in investigating are universal. While the nature of violations may differ from one organization to another, and a few specifics of what a government agency may request might also differ, good investigative practices apply across a wide spectrum of investigations.
I don’t say this to say there isn’t value in having an investigator experienced in the compliance aspects of the underlying subject matter. This experience can have many benefits in directing an investigation.
However, when making hiring or outsourcing decisions, strong investigative experience in a different field should not be undervalued. It almost always takes longer to become a sound investigator than it does to learn the details of the compliance aspects of the investigation. Ideally, our investigators have both strong investigative skills and subject matter expertise. But I wouldn’t ever sacrifice investigative skills. There are just too many things that can go wrong with a poorly performed investigation.
1 Theresa Defino, “Where’s the Proof? NSF OIG Provides Insights on Crafting That All0Omportant Investigation Report,” Report onResearch Compliance 20, no. 10 (September 2023), https://compliancecosmos.org/wheres-proof-nsf-oig-provides-insights-crafting-all-important-investigation-report?_zs=aahnM1&_zl=2H4F7.
2 Valerie J. Hillgren, The Institution’s Investigation Report: Best and Worst Practices, National Science Foundation, Office of Inspector General, accessed October 3, 2023, https://oig.nsf.gov/sites/default/files/document/2023-08/2023%20RIAI%20Workshop%20
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