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ARCHIVED – Update on Strengthening Integrity in Research and Scholarship

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Introduction

In recent years, the Government of Canada has made significant investments to position our country in the global, knowledge-based society and economy. These investments were made to mobilize science and technology to Canada’s advantage, ensure high quality research and training, stimulate the economy, generate new jobs and improve the quality of life of Canadians. The R&D achievements in Canadian institutions are impressive, as is Canada’s high ranking in the quality of its research and post-secondary training.1 Research excellence and creativity are now understood as key assets for national success and international competitiveness. Indeed, the Organisation for Economic Co-operation and Development (OECD) has stated that, far from being a luxury affordable only during prosperous economic times, research and innovation must now play a key role in the recovery of economies around the world.2

Integrity in research is directly linked to Canada’s performance in R&D and to Canada’s reputation in the international research community. Research integrity is also directly linked to the efficient use of taxpayers’ dollars. Individual cases of research misconduct can have negative impacts on the advancement of knowledge, lead to the commercialization of unsafe products or processes, and erode the public’s trust in research. The research community, those who depend on and use research results, and taxpayers need to know there is integrity in the research process, that standards are being met and that any anomalies are being dealt with effectively.

Estimates for rates of research and scholarly misconduct vary widely.3 While no similar study exists for Canada, based on statistics on cases involving the three granting agencies, the incidence in Canada of serious cases of misconduct requiring investigation or action appears to be very low [Natural Sciences and Engineering Research Council of Canada (NSERC), This link will take you to another Web site Canadian Institutes of Health Research (CIHR), This link will take you to another Web site Social Sciences and Humanities Research Council of Canada (SSHRC)]. In a recent report commissioned by the Canadian Research Integrity Committee (CRIC), it was noted that, on average, large universities report approximately two allegations per year, while small universities report one allegation every two years or so.4

Background on the Research Integrity Review

NSERC, CIHR, SSHRC (the Agencies), along with the Association of Universities and Colleges of Canada (AUCC), remain committed to improving the policy framework for research and scholarly integrity, and financial accountability. The report on the review of the integrity policy framework was prepared by NSERC, SSHRC and AUCC for the Minister of Industry and made public in October 2009. CIHR provided input on the draft report and has been participating in the development and implementation of a related action plan. The report concluded that the overall approach to research integrity was sound and identified four key action areas to strengthen the policy framework: 

  1. Clarify the Agencies’ role regarding integrity.
  2. Update and strengthen the current research and scholarly integrity policy in order to ensure that it reflects the highest standards of integrity and provides increased clarity of terms, roles and responsibilities.
  3. Improve the effectiveness of the implementation of the Policy and increase its transparency, in order to ensure that all cases are dealt with effectively and that all stakeholders are well informed.
  4. Update and strengthen the current Financial Policy in order to ensure that it reflects the highest standards of accountability and provides increased clarity of terms, roles and responsibilities.

This update is the first of a series of periodic updates on work being done to address these key action areas. 

Actions Taken to Strengthen Research Integrity

The Agencies are implementing a number of improvements to their internal procedures and are clarifying certain existing requirements related to the current research integrity and financial policy framework. These actions do not involve changes to the institutions’ policies. The relevant recommendations from the integrity report appear below in the boxes. The Agencies’ response, and actions taken and planned, follow each recommendation.

1. Clarify the Agencies’ role


Clarify the Agencies’ role regarding integrity in order to determine a) whether the Agencies are fulfilling all their responsibilities and exercising all their authorities, including holding institutions and researchers fully accountable, and b) whether their current legislated roles, responsibilities and authorities are appropriate and sufficient for the level of oversight and accountability required.

Action No. 1

As part of the process of revising the integrity policy framework, the Agencies will review their role in consultation with the community and considering:

  • the results of an upcoming report prepared by the Council of Canadian Academies (CCA)
  • the HAL report commissioned by the Canadian Research Integrity Committee (CRIC)
  • advice from the Research Integrity Advisory Group (RIAG), a committee to be established by the Agencies later in 2010   
    (See below for more information on the CCA and RIAG).

The following clarifies and summarizes the current roles and responsibilities of the Agencies and institutions within the framework.

As a condition of eligibility to apply for and receive agency grant and award funding, institutions sign the Memorandum of Understanding: Roles and Responsibilities in the Management of Federal Grants and Awards (MOU). Schedule 4 of the MOU requires that institutions have in place their own policy and process that comply with the Tri-Council Policy Statement: Integrity in Research and Scholarship (TCPS-I) and the Framework for Tri-Council Review of University Policies Dealing with Integrity in Research. Prior to becoming eligible and signing the MOU, the institution’s research integrity policy and process is reviewed and approved by the Agencies. Institutions are required to promote integrity, investigate allegations in accordance with their policies, and inform the appropriate agency of their findings of misconduct if agency funding is involved. (This practice of making institutions primarily responsible for investigating allegations is followed by many developed countries.) 

The Agencies do not have regulatory authority to investigate cases of alleged misconduct and cannot substitute the institution’s conclusion with different findings. The Agencies follow-up with institutions to monitor progress and time lines of specific cases, and can request clarification of the institution’s process and findings. Based on the institution’s findings, the Agencies can take further actions, for example, by requiring that grant/award funds be reimbursed and by designating the researcher ineligible to compete for further funding or to participate in peer review committees. Each agency has instituted an independent research integrity committee that makes recommendations on how to deal with individual integrity cases (see NSERC, This link will take you to another Web site CIHR and This link will take you to another Web site SSHRC). In accordance with Treasury Board policy, the Agencies are responsible for referring any cases where there is possible criminal activity to the appropriate authorities. 

The Agencies have developed a common set of elements they consider when determining the actions to be taken in confirmed cases of misconduct involving agency funds. These factors include, but are not limited to:

  • the nature and gravity of the breach
  • the impact of the breach on the agency
  • findings and conclusions of the institution and actions/sanctions taken by the institution
  • the level of experience of the respondent
  • previous breaches by the respondent
  • actions taken in similar cases

Each agency notifies the respondent and the institution involved of its decision. The Agencies comply with the This link will take you to another Web site Privacy Act and the This link will take you to another Web site Access to Information Act and cannot share with other organizations, or make public, personal information about specific cases.

2. Update and strengthen the current research and scholarly integrity policy

Specify the requirements for the content of institutions’ investigation reports of misconduct cases.

Action No. 2

The following clarifies the Agencies’ specific requirements for the content of institutions’ reports to the Agencies:

TheTri-Council Policy Statement on Integrity in Research and Scholarship, the Framework for Tri-Council Review of Institutional Policies Dealing with Integrity in Research and the Memorandum of Understanding Roles and Responsibilities in the Management of Federal Grants and Awards each contain statements about the reports that institutions must provide to Agencies with respect to the institutions’ investigations of allegations of misconduct.

Once the report is received, agency staff review it to determine if the investigation conducted was consistent with the university’s policy (and, as a consequence, with the TCPS-I and its Framework). The Agencies have received various types of reports, from the institution’s full investigation report and appendices to short, one-paragraph letters. While the latter is incomplete and not adequate, the former generally provides more information than is required by the Agencies.

Institutional reports to the relevant agency should detail:

  • the process and time lines followed for the enquiry and/or investigation
  • the specific allegation(s), a summary of the information that substantiates the finding(s) and conclusion(s) that were reached; specifically whether or not misconduct was concluded to have occurred
  • the institution’s recommendations and actions taken

The institution’s report should not include:

  • information that is not related specifically to the finding of misconduct or to agency funding and policies
  • private information about third parties involved in the case

The report should be written for a generalist audience and provide the context for any specific research-related discipline practices, conventions or requirements that had a bearing on the case.

The institution’s report submitted to the relevant agency should be copied to the respondent in order to ensure a transparent process. It must be sent to the relevant agency within 30 days of the completion of the investigation. The institution and/or researcher may not enter into confidentiality, or other agreements related to an investigation or audit, that prevent the institution from meeting the Agencies’ requirements.

3. Improve the effectiveness of the implementation of the Policy and increase its transparency

Develop harmonized procedures and review cases in order to ensure a consistent approach, and make their harmonized procedures publicly available. This will include a common approach for receiving and transmitting allegations.

Action No. 3

The Agencies have developed the Tri-Agency Process for Addressing Allegations of Non-Compliance with Tri-Agency Policies to ensure consistency in how cases are handled. This process is used for allegations of non-compliance with different Agencies’ policies, such as integrity, financial and ethics.

Identify measures that could be taken to share more information on specific cases among the Agencies and/or provide the public with increased information about confirmed cases of misconduct, taking into account applicable federal and provincial laws.

Action No. 4

The Agencies have issued summaries of confirmed cases of misconduct that do not include personal information about the individuals involved. The Agencies will regularly issue information on cases on their Web sites and in newsletters.  

Determine which types of integrity cases should be referred to legal authorities.

Action No. 5

The Agencies can only make this determination on a case-by-case basis, in accordance with Treasury Board policy and, if necessary, in consultation with legal counsel.

4.  Update and strengthen the current Financial Policy

Clarify what types of cases involving misuse of agency funds must be investigated by institutions and referred to their respective integrity review committees for consideration, and what actions will be taken when there is a finding of misuse of grant funds.

Action No. 6 

The following clarifies the types of cases that must be reviewed by institutions and by agency integrity review committees.

  • Policies on the use of grant or award funds, including the financial management responsibilities of grantees and institutions are outlined in the Tri-Agency Financial Administration Guide and Schedule 1 of the Memorandum of Understanding Roles and Responsibilities for the Management of Federal Grants and Awards (MOU).
  • In cases where an agency receives an allegation of non-compliance with the Tri-Agency Financial Administration Guide, the Tri-Agency Process for Addressing Allegations of Non-Compliance with Tri-Agency Policies applies. The agency may request that the grantee’s institution investigate the matter and submit a report to the agency.
  • If the institution concludes that funds were used inappropriately due to honest error or misunderstanding, the Agencies will request that the error be corrected and may require reimbursement of funds to the grantee’s account or to the agency.
  • If the institution confirms that funds were used in a manner contrary to the Tri-Agency Financial Administration Guide and that misconduct has occurred, a report must be provided to the agency involved and the case presented to the agency’s integrity committee for review and a recommendation. The agency may then decide to take certain actions, including terminating the grant or declaring a researcher ineligible from applying for future funding. 
  • In cases where an institution directly receives an allegation that a researcher has not complied with the Tri-Agency Financial Administration Guide, the agency involved should be informed. The process described above is then followed.
  • If at any time evidence of possible criminal activity is found, the agency must immediately refer the matter to the appropriate authorities, in accordance with Treasury Board policy.

Develop, and make publicly available, harmonized procedures for dealing with allegations of misuse of grant funds.

Action No. 7

As noted above (Action No.3), the Tri-Agency Process for Addressing Allegations of Non-Compliance with Tri-Agency Policies applies to allegations of misuse of grant funds. This process ensures consistency in how cases are handled and is used for allegations of non-compliance with all Agencies’ policies, such as integrity, financial and ethics.

Action No. 8

The Agencies have standardized their requirements for institutional reports, as outlined above (Action No.2). These requirements apply to reports on allegations of non-compliance with different agency policies, including misuse of fund cases. In financial cases, the agency involved may request that the institution provide clarification or additional information, such as supporting documentation (e.g., receipts, e-mails).

Next Steps

In  October 2009 the This link will take you to another Web site Council of Canadian Academies (CCA) convened an expert panel to respond to the Minister of Industry’s request for an assessment on “the key research integrity principles, procedural mechanisms and practices, appropriate in the Canadian context, that could be applied across research disciplines at institutions receiving funds from the federal granting agencies.”

The CCA assessment will include advice on processes and mechanisms for research integrity, as well as a definition, and is expected to be completed in September 2010. At that time, the Agencies will convene a Research Integrity Advisory Group (RIAG), to help guide the development of a new integrity policy framework for the Agencies. The RIAG’s membership and terms of reference will be made public. In this way, the work of the Agencies will not impede or duplicate the CCA’s activities. It is expected that a revised Tri-agency draft policy on research integrity will be completed and ready for consideration by stakeholders in time for their annual meetings in spring 2011. With the assistance of the AUCC, comprehensive consultations on the revised draft policy and processes will be undertaken in 2011 with a wide range of stakeholders.

The revised Tri-Agency policy is expected to be finalized by January 2012. Institutions will be asked to ensure that their institutional research integrity policies conform with the revised policy within one year of the launch date.

Closing

It is an essential value of the research community to ensure the integrity of research. It is also important to Canadians, given the significant investments made by the federal government in research and the important contribution research makes to our society. We are confident that, working together with institutions and researchers, we will make an effective research system even better.

The completed actions outlined in this update, and the plan forward, represent our continuing commitment to due diligence to ensure that our integrity policy is up to the highest standards of accountability. 

1Science, Technology and Innovation Council: This link will take you to another Web site State of the Nation in 2008 (2009).

2OECD Policy Response to the Economic Crisis: Investing in Innovation for Long-Term Growth. June 2009. This link will take you to another Web site www.kooperation-international.de/en/indonesien/themes/info/detail/data/41963/backpid/12/?PHPSESSID=c332.

3JM Ranstam, 2000, Control Clinical Trials 21, 5:415-27; Geggie, 2001 J Medical Ethics 27, 5:344-6; Gardner, 2005, Contemp Clin Trials 26, 2:244-51; Pryor, 2007, J Med Ethics 33, 6:365-9; Martinson, Anderson, DeVries, 2005, Nature 435, 737-38.

4The State of Research Integrity and Misconduct Policies in Canada. Report by Hickling Arthurs Low, commissioned by the Canadian Research Integrity Committee.
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