Case Study in Review Integrity: Sharing an Application Being Reviewed

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A series to raise awareness, encourage dialog and inspire creative problem solving of the challenges in maintaining integrity in peer review

Sharing an application with anyone who has not been officially designated to participate in the peer review process is a big no-no. It undermines the integrity of peer review. It disregards the confidentiality that is required of peer reviewers, who specifically sign a confidentiality agreement before accessing the applications. And it is specifically prohibited by NIH peer review policy.

We have a case for you where this sharing occurred (based on a true story; details have been changed slightly and names have been fictionalized). Read on to see how it ended.

Researcher A had been invited by Researcher Z to collaborate on an upcoming project by providing expertise for a new grant application where Researcher Z was a Principal Investigator.  Researcher A gave suggestions for an imaging protocol in the application. During the back and forth, Researcher A learned that Researcher Z was reviewing a grant application with an imaging protocol that might be helpful.  Researcher Z then shared a screen shot of the protocol, copied it and emailed it to Researcher A.

How did Researcher A react? Researcher A reported the incident to NIH officials and provided the email from Researcher Z and screenshot of the imaging protocol from the application.  Researcher A informed NIH that Researcher Z had suggested that they should copy and then slightly modify the section’s wording for Z’s application.

Researcher A reported having refused to comply with Researcher Z’s suggestion and ended up recommending a different imaging protocol for Z’s application.

In response, NIH leadership terminated Researcher Z’s service in NIH peer review indefinitely. NIH also informed the Vice President for Research at Z’s university about the case details and the violations.

Thus, it appears that Researcher Z 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.  Researcher Z’s actions appear to us to be a blatant breach of review confidentiality for their own gain, despite awareness of NIH policies that prohibit such actions. 

Consistent with NIH policy (e.g., NOT-OD-15-106 and NOT-OD-18-115), NIH is notifying you as a senior leader in Researcher Z’s institution.  Because the integrity concerns raise questions about Researcher Z’s authority and responsibility as a designated PI on NIH applications and awards, NIH is requesting that you review Researcher Z’s actions as the PI on NIH grant applications and awards to assess the (potential) impact.

Also, 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), such as requesting NIH’s approval for a change in PI status.

The Vice President for Research at Z’s university ordered an investigation of the matter. In their formal response to NIH, the institution stated that during the interview while Z admitted to sending the screenshot to Researcher A, Z denied the implication that Z had suggested Researcher A use the imaging protocol for their upcoming application submission.  Instead, Z explained that the screen shot was sent as a “teaching tool.”

The institution noted it was taking action, including imposing additional mandatory training and enhancing oversight of Researcher Z’s NIH-funded work. The institution also reassured the NIH that faculty and staff were receiving regular training in peer review confidentiality as part of the required curriculum in responsible conduct of research.  Finally, the institution sent out a dedicated “must read” memo to all staff reminding them of peer review integrity rules.

For more, see our Taking Action – Case Studies in NIH Peer Review Integrity website.

3 Comments

  1. Amazing peer-review and grant applications privacy policy snapshot; the pragmatic researcher example involving the principal investigator-leadership-data sharing provided critical research insights!

  2. Based on how this case is presented, researcher A gets off a bit too easy here. More than likely, Dr. Z did not send the screenshot completely unprompted, but following a discussion on the merits of the imaging protocol in Dr. Z’s review assignment. Dr. A should have made it absolutely clear that he/she does not want to hear about this protocol, which would have likely ended all further shenanigans.

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