A series to raise awareness, encourage dialogue and inspire creative problem solving of the challenges in maintaining integrity in peer review
What happens when a former colleague contacts you, a reviewer, out of the blue to ask if the application on which he is a principal investigator could be treated favorably at the review meeting? Do you brush off the investigator and figure you will not let the contact influence your review of that application? Or do you instead immediately notify NIH?
Intrigued? We have a case for you (based on true stories, details have been changed slightly and names have been fictionalized). Read on.
Dr. Miller, a reviewer recently appointed to an NIH study section, was surprised to get an email from a former lab colleague, Dr. Johnson. They had not kept in touch over the years. As it so happened, Johnson was designated as a PI on one of the applications Miller was reviewing. Johnson mentioned their common scientific interests and went on to ask if any of the other applications on the study section involved members of the ‘old gang.’ Perhaps, he suggested, those applications could get favorable consideration from Miller and other reviewers.
Miller was stunned and responded that he did not know and could not help. To which Johnson replied, “It’s not wrong, it’s how we help each other. And remember, I know a lot of people.”
The exchange left Miller feeling unsettled. Even if he declared a conflict of interest with the application on which Johnson was a PI, he could still be seen as responsible for the outcome of the review because conflicts of interest are strictly confidential. Moreover, Johnson’s message implied that Miller should convince other study section members to look favorably on the application. Finally, Miller interpreted Johnson’s message to be a veiled threat; ‘knowing a lot of people’ could mean that Johnson would marshal powerful people in the field against Miller if the outcome were not favorable.
Miller immediately forwarded the email exchange to the NIH scientific review officer (SRO) running the NIH study section on which he serves.
As instructed, the SRO confidentially forwarded the exchange to her Institute’s research integrity officer (RIO) for evaluation and possible actions. In turn, the RIO confidentially shared the information and her recommendations with the NIH Office of Extramural Research (OER).
NIH indefinitely terminated Johnson’s service in NIH peer review and the application listing Johnson as PI was deferred to another study section for review. NIH OER leadership also informed the Vice President for Research at Johnson’s university about the details of the case and the violations.
It appears that Dr. Johnson may have deliberately violated NIH peer review policies (NOT-OD-15-106 and NOT-OD-18-115) and attempted to undermine the integrity of the NIH peer review process in violation of NIH policy.
Consistent with NIH policy (e.g., NOT-OD-15-106 and NOT-OD-18-115), NIH is notifying you as a senior leader in Dr. Johnson’s institution. Because these integrity concerns raise questions about Dr. Johnson’s authority and responsibility as a designated PI on NIH applications and awards, NIH is requesting that you review Dr. Johnson’s actions as the PI on NIH grant applications and awards to assess the (potential) impact.
Also, because of this situation, we are concerned that staff in your institution may not be fully cognizant of their responsibilities and of the potential consequences of integrity breaches.
NIH is requesting that you respond in writing within 30 days, addressing any impact on such applications and awards and confirming any responsive action(s) you may take.
Upon receiving this information, the Vice President for Research at Johnson’s university took steps to address this violation. A formal letter to NIH leadership stated that the institution had completed an investigation into the matter and confirmed that Johnson had improper communications with an individual serving on an NIH study section. Therefore, Johnson would be:
- prohibited by the institution from submitting any applications or receiving any support from the NIH for two years,
- prohibited by the institution from serving on an NIH or other federally chartered study section for three years,
- required by the institution to complete a course in responsible conduct of research, and
- subject to administrative penalties at the institution.
Furthermore, the institution developed plans to enhance its already existing faculty training to include a module on peer review integrity.
As you can see, NIH is taking issues of integrity in peer review seriously. We are highlighting particular case studies in an effort to be transparent in our actions and intent. We appreciate the actions taken by reviewers like Dr. Miller in recognizing the violation and informing us immediately.