Imagine you are reviewing an application for an NIH study section meeting, and you come across an application that seems just a bit too familiar. The scientific question falls within your wheelhouse. The methods and strategies seem spot on. And isn’t that how you format your text? In this case study, we will discuss how plagiarism in the grant application process is handled at NIH and remind the research community about the importance of maintaining confidentiality of the peer review process. The scenario presented is based on real-world events, with all names and identifiers removed or changed.
Dr. ABC found themselves in this situation. While serving as a peer reviewer, they were assigned an application containing sections that looked very similar to their own application submitted several years prior. The current application identifies Dr. XYZ as the project’s lead, who also serves as principal investigator on other NIH awards. ABC immediately contacted the NIH Scientific Review Officer overseeing the study section to share their concerns.
The Scientific Review Officer asked the NIH Office of Extramural Research (OER) to take a look and see if plagiarism may have occurred with XYZ’s application. Upon closer inspection, the text in the Procedures and Data Collection sections were found to be too similar to text from ABC’s applications to be coincidental.
Looking back at the roster from when ABC’s original application was reviewed, NIH staff identified a few long-term collaborators of XYZ’s. Those reviewers had had access to ABC’s application at that time. Maybe that was not a mere coincidence either. At this point, we referred the preliminary findings to the HHS Office of Research Integrity (ORI), who have the authority and responsibility to review and monitor investigations of research misconduct allegations involving NIH funding. Though ORI had the lead, we still worked closely together with them.
ORI reached out to XYZ’s institution next, as they were the applicant. With consent from ABC and their institution, ORI showed them the two applications along with the document-to-document comparison report.
XYZ’s institution then began their own internal research misconduct proceedings as part of the ORI review. They engaged with XYZ throughout the process to learn more. During those conversations, XYZ admitted to receiving ABC’s application from their collaborator, who served as a peer reviewer. XYZ also admitted to copying parts of that application into their own application.
The institution was in regular communication with OER too because the investigation involved a pending NIH application. When the institution’s investigation was complete, the institution informed us they made findings of research misconduct against Dr. XYZ, and also retracted their application. As a result, they prohibited XYZ from serving on NIH committees or being designated as principal investigator on applications for three years. They required XYZ to certify in writing that the ideas, results, and words were properly attributed in grant applications, and to develop and teach a seminar on research misconduct.
We are grateful to reviewers who raise any concerns about the integrity of the peer review process or applications with NIH Review staff. As explained more in the related required reviewer training, these concerns are taken seriously, especially when plagiarism or other forms of research misconduct are involved.
Importantly, we too will take actions based on the severity of the peer review violation (see NOT-OD-22-044). Separate from the steps that XYZ’s institution took, we removed XYZ from serving as a peer reviewer going forward. A committee of NIH grants management and program staff will also look at all of XYZ’s progress reports and other related grant submissions for the next three years. If no additional issues are found, then NIH will allow XYZ to again be designated on grant applications.
What about the collaborator?
We reached out to their institution as well. As part of that institution’s investigation, the collaborator admitted to accessing ABC’s application through their peer review service, retaining peer review materials after the review meeting ended, and sharing those materials with people unaffiliated with the study section. The institution fired the employee, and we removed them from review service.
We are grateful to those who serve in peer review. However, peer review service is a privilege, extended at NIH’s invitation. Those who undermine the confidentiality rules (such as keeping any relevant materials after the meeting is over) will not be invited to serve in NIH peer review again. These and other requirements are outlined in the confidentiality agreement that must be certified and signed before serving as a reviewer. Upholding these rules is critical for ensuring that researchers feel they can trust NIH with their candid, sensitive, and proprietary ideas. It is important to remind reviewers about the consequences when such a breach in integrity happens.
More case studies on research integrity may be found on our website.
Editorial note, December 12, 2023: Institutions, not NIH, are responsible for making personnel decisions related to their employees. Oftentimes, the identified non-compliance extends to institutional faculty or staff rules or policies. NIH will discuss the impact on NIH awards and work with the institution on any needed grant actions.