NATIONAL SCIENCE FOUNDATION OFFICE OF INSPECTOR GENERAL OFFICE OF INVESTIGATIONS CLOSEOUT MEMORANDUM 11 Case Number: A04050026 11 Page 1 of 1 We identified two proposals1submitted from a community college2with text copied verbatim from several sources. The proposals had a single principal investigator PI)^ in common, one having a single CO- PI^ and the other two C O - ~ 1 s .The ~ community college did not have a research misconduct policy and the PI was the head of the grants office at the institution. Therefore we did not refer the investigation to the institution. Our investigation showed that the PI was the responsible author for the text copied and the lack of appropriate citation. Based on our investigation, we presented NSF with the attached investigation report and recommended that NSF: send a letter of reprimand with a finding of research misconduct to the PI; require the PI to certify completion of an ethics in scientific research course prior to submitting any future proposals to NSF; and require the PI to certify that proposals he submits to NSF as PI, Co-PI, or otherwise as an author do not contain plagiarized material for one year. In the attached letter from the NSF Deputy Director, NSF has made a finding of research misconduct, required the PI to certifi completion of a training course of ethics in scientific research, and required the PI to certify that any proposal he submits as PI or Co-PI does not contain plagiarized material until December 15,2006. NSF OIG Form 2 ( 1 1102) NATIONALSCIENCE FOUNDATION 4201 WILSON BOULEVARD ARLINGTON, VIRGINIA 22230 OFFICE OF THE DEPUTY DIRECTOR JAN 1 3 2006 ' MATI, --RETIJRN RECEIPT REQLJESTl3.D Re: Notice ofMisconduci in Sciell ce Dererln illation ear- - On Februarv. l., 2003.. vou submitted a uro~osalto the National Science Foundation A 2 ("NSF") entitled On October 15,2003, you submitted another proposal to NSF ed)l-(tenit 0 As documented in the attached Investigative Report prepared by NSF's Office of Inspector General ("OIG"), both of these proposals contained plagiarized text. Under 1VSF7sregulations, "research misconduct" is defined as "fabrication, falsification, or plagiarism in proposing or performing research funded by NSF .. ." 45 CFR 5 689.1 (a). NSF defines "plagiarism" as "the appropriation of another person's ideas, processes, results or words without giving appropriate credit." 45 CFR 5 689.1(a)(3). A finding of research misconduct requires that: (I) There be a significant departure from accepted practices ofthe relevant research community; and (2) The research misconduct be committed intentionally, or knowingly, or recklessly; and (3) The allegation be proven by a preponderance of evidence. 45 CFR 3 689.2(c). In the two proposals you submitted to NSF, you misappropriated text from source documents into the proposals without providing proper attribution for such text. By submitting proposals to NSF that copy the ideas or words of another without adequate attribution, as ---- --deferibedin#x-QG hwstigative-Reportiyou lnisrepresentedsomeone-4x5-work as your-own. - - -- Your conduct unquestionably constitutes plagiarism. I therefore conclude that your actions meet the definition of "research misconduct" set forth in NSF's regulations. Pursuant to NSF regulations, the Foundation must also determine whether to make a finding of misconduct based on a preponderance of the evidence. 45 CFR $ 689.2(c). After reviewing the Investigative Report, NSF has determined that, based on a preponderance of the evidence, your plagiarism constituted a significant departure from accepted practices of the relevant research community. I am, therefore, issuing a finding of research misconduct against you. NSF's regulations establish three categories of actions (Group I, 11, and In) that can be taken in response to a finding of misconduct. 45 CFR $689.3(a). Group I actions include issuing a letter of reprimand; conditioning awards on prior approval ofparticular activities from NSF; requiring that an institution or individual obtain special prior approval of particular activities from NSF; and requiring that an institutional representative certify as to the accuracy of reports or certifications of compliance with particular requirements. 45 CFR $689.3(a)(l). Group II actions include award suspension or restrictions on designated activities or expenditures; requiring special reviews of requests for funding; and requiring correction to the research record. 45 CFR $689.3(a)(2). Group 111actions include suspension or termination of awards; prohibitions on participation as NSF reviewers, advisors or consultants; and debarment or suspension from participation in NSF programs. 45 CFR 9 689.3(a)(3). In determining the severity of the sanction to impose for research misconduct, I have considered the seriousness of the misconduct; our determination that it was committed knowingly; the fact that your misconduct had no impact on the research record; the fact that your misconduct was an isolated incident as opposed to a part of a pattern; your willingness to accept responsibility for your actions; and the contrition that you demonstrated during the course of the investigative process. I have also considered other relevant circumstances. 45 CFR $ 689.3 (b). I find your plagiarism to be serious because, as the Director of Grants at your institution, you are the individual responsible for submitting grant proposals to NSF and other Federal entities. There are, however, several mitigating factors that must be considered. First, you provided citations for much of the copied text at issue, but simply failed to distinguish your text properly from the copied text. Second, you did not author the proposals at issue for personal gain; rather, you did so as a favor to colleagues who did not have sufficient time to write them themselves. In addition, you cooperated fully with the OIG investigation, and accepted full responsibility for any plagiarism that occurred. I, therefore, take the following actions: From the date of this letter until December 15, 2006, you must certify that any proposal . .. .. ., , - ,. .. .. ., you submit...as a.....PI ..or. co-PI .does , . .. .. .. . not contain plagiarized material. .. -..- . ... . - . - -. . -.. ..-. . .. . .. You are required to complete a training course on ethics in scientific research before submitting any additional proposals to NSF. You must certify in writing to the OIG that such training has been completed. Under NSF's regulations, you have 30 days after receipt of this letter to submit an appeal of this decision, in writing, to the Director of the Foundation. 45 CFR $689.10(a). Any appeal should be addressed to the Director at the National Science Foundation, 4201 Wilson Boulevard, Arlington, Virginia 22230. For your information we are attaching a copy of the applicable regulations. If you have any questions about the foregoing, please call Assistant General Counsel, at (703) 292-8060. Sincerely, Kathie L. Olsen Deputy Director Enclosures - Lnvestigative Report - 45 C.F.R. 689 National Science Foundation Office of Inspector General Confidential investigation Keport Case Number A04050026 CONFIDENTIAL NSF OIG FORM228 (1103) Summary The Office of Inspector General (OIG) has concluded that the subject1 committed plagiarism in two proposals submitted to NSF. The subject is the PI on both proposals and Director of Grants at the community college2 that submitted the proposals. Because the subject's institution does not have a research misconduct policy, OIG did not refer the investigation to the institution and conducted its own investigation. OIG concludes that the preponderance of evidence supports a finding of research misconduct and recommends that NSF: send a letter of reprimand to the subject informing him that NSF has made a finding of research misconduct; require the subject to certify the completion of a course on ethics in scientific research before submitting any proposals to NSF on which he is a principal investigator (PI), co-principal investigator (Co-PI), or otherwise contributes as an author; and require the subject to certify that proposals he submits as PI, Co-PI, or otherwise contributes as an author, to NSF do not contain plagiarized material for 1 year commencing with the date of NSF's finding of research misconduct. OIG's Inquirv OIG received an allegation of plagiarism regarding a proposal3(Proposal 1) the subject submitted to NSF. The proposal identified the subject as both the PI and the authorized organization representative (AOR) with one CO- PI^ listed (Co-PI 1). OIG's analysis of Proposal 1 led to the identification of several possible source documents5for the allegedly copied material. Analysis of the subject's other proposals to NSF revealed an earlier proposal6 (Proposal 2) containing apparently copied text.7 The sub'ect was also d the PI and AOR on Proposal 2 along with two Co-PIS (Co-PI 2' and Co-PI 3 ), neither of whom appeared on Proposal 1. Although some of the potential source d o c ~ m e n t s ' ~ identified by OIG were included as references within the proposal, blocks of text - 45 Tabs 4-7, Source Documents A through D identified for Proposal 1. 6 See Tab 2, Tabs 8-12. Source Documents E through K identified for Pro~osal2. 1u Tabs 4-12. Source documents identified by OIG for the allegedly copied text. appeared to have been copied verbatim without quotation marks, indentation, or other means of distinguishing the copied text from the subject's own text. In those passages with citations, the citations did not clearly lead the reader to the source material. All told, the two proposals contained approximately four pages of copied text. OIG wrote to the subject'' and each of three Co-PIS individually12to inquire about the apparently copied text and received responses from each indi~idual.'~ All of the responses, including the subject's, attributed authorship of the questioned sections of the proposals to the subject. The subject explained the instances of questioned text in various ways: 1) he provided the citation but failed to use quotation marks or indentation, 2) the citation was inadvertently omitted during text revision, 3) his paraphrasing was imperfect, and 4) there was prior authorization by the author of one source to use the material without attribution through an intellectual property licensing agreement.I4 As part of the inquiry, Co-PI 1 provided a copy of a portion of a licensing agreement to support the prior authorization explanation; however, OIG' s' understanding of the excerpt of the agreement is that the .intellectualproperty rights licensed did not include a waiver of acknowledgement as the source of the original material. The subject and Co-PI 1 both wrote that the allegations, with respect to Proposal 1, were a case of poor citation and "cut and paste errors" rather than They also indicated that the subject wrote Proposal 1 using information that Co-PI 1 supplied to him. The subject also pointed out that some of the material in Proposal 1 came froin a article, which must have copied the sources identified by OIG.'~ Co-PI 2 and Co-PI 3 both provided brief responses indicating that the subject wrote Proposal 2 using information they provided to him.'' Their responses were consistent with the subject's regarding authorship and a lack of intent to deceive.lg During the review of the proposals, OIG also noted that although the subject was the PI, he had not submitted biographical information as required for senior personnel by Section II.C.2.f of the NSF Grant Proposal Guide (GPG). At OIG's request, the subject provided a resume, which indicated that he is the Director of the Grants at the institution as well as a professional grant writer." The subject stated that he provided grant writing Tab 1. 12 OIG's inquiry letters to each of the Co-PIS are essentially identical to the letter sent to the subject (Tab 1) except that the questions were restricted to the specific proposal on which the Co-PI was named. l 3 Initially, all four responded jointly in a letter signed only by the subject (Tab 13, Joint Response). Because that letter bore only the signature of the subject, OIG contacted each of the Co-Pls requesting individual responses to c o n f i that they had indeed been party to the joint response. OIG ultimately received individual responses from each of the Co-PIS. See Tabs 15-18. l4 Tab 13, pages 2-3. l5 Tab 16, page 3. l6 Tab 13, page 3; Tab 15, page 2; and Tab 16, page 1. l7 Tab 13, page 3. l8 Tab 17, page 1; and Tab 18, page 1. l9 Tab 17, page 1; and Tab 18, page 1. 20 Tab 13, page 4-5. services for the faculty because they "do not have sufficient time to spend on physically submitting the proposal . . . ."2' The subject told OIG that he had difficulty uploading proposals into FastLane for the faculty.22 He wrote that he "raised the issue with the FastLane people about four or five years ago, and, on their recommendation, [he] also became the PI on all grants submitted, but in name only . . . .,923 Because the responses of the subject and his three co-PIS did not adequately explain the extensive use of copied text, OIG determined the need for a detailed investigation. The subject appeared to be the sole author for the text in question and its final preparation for submission; therefore, OIG did not include any of the three Co-PIS as subjects of the detailed investigation. OIG's Investigation The subject's institution does not have a research misconduct policy; therefore OIG did not refer the investigation to the institution. Consequently, OIG conducted the investigation. In addition to the documentary evidence collected during the inquiry, the investigation also included an interview with the subject.24 Interview with the subiect2' During the interview, OIG learned the subject is the only employee in the Grants Office at the i n ~ t i t u t i o nand , ~ ~is the only institution employee who submits proposals.27 He works exclusively with grants from Federal agencies2' and provided OIG with a list of proposals submitted to Federal agencies over the previous three years.29 He came out of retirement to take this position and also writes grants for and consults with an R organization that assists autistic ~hildren.~'He also assists the institution's resident with speech writing, strategic planning, and responses to congressional inquires. The subject said that there was no excuse for what happened and that he did not know how it happened.32 He took full responsibility for the failure to provide appropriate citations to source documents noting the pressure of impending deadlines for s u b m i ~ s i o n .OIG ~ ~ asked about his definition of plagiarism to which he responded that 21 Tab 13, page 2. zz Tab 13, page 2. See also Tab 22, pages 1-2. 21 Tab 13, page 2. 24 Tab 22, Summary of the subject's interview with OIG staff. 2S Tab 22. 26 Tab 22, page 1. 27 Tab 22, page 2. 28 Tab 22, page 1. 29 Tab 26. 30 Tab 22, page 1. 3' Tab 22, page 1. 32 Tab 22, page 2. 33 Tab 22, page 2. CONFIDEN11AL CONFIDENIlAL he saw it as taking other peoples' research and using it as his own, without attribution. 34 The subject asked that NSF take any actions against him personally and not the institution.35 The Subject's Newsgroup Postings OIG identified several postings, by the subject, to a discussion thread between May 2000 and May 2001 on . 36 The postings contained the subject's name as the source of the posting with his current email address at the institution. OIG found that the subject provided formal citations to source material and quoted text offset from the subject's original text despite the informal nature of po stings to a discussion 37 thread. OIG also found statements in which the subject encouraged another grant writer to seek periodic refresher training, noting his own need to do so "to eliminate bad habits I tend to get into and unnecessary shortcuts I tend to take,,;38 noted his preference for working on grants up until the last minute;39 and reminded someone to "paraphrase ... giving credit of course.,,40 Analysis o(proposal text We address the questioned passages in summary form organized by issue, using the cross-referencing scheme ofletters used in the initial inquiry letter to the subject to identifY sections of source text. We note that none ofthe passages contain technically constrained language limiting the expression of the content to the particular words used. Text not cited. The subject did not include citations for passages F, G, H, J and K, in Proposal 1. The subject copied passage F, approximately two lines, from a Japanese professional association webpage,41 omitting one phrase from the source document. The source document for passages G, H, and J4 is a website attributed to a 43 Federally Funded Research and Development Center. Passages G and J were lists of information modified to change verb tense with accompanying introductory material. Passage H was strictly textual material with de minimis alteration from the original text. 34 Tab 22, page 2. 3S Tab 22, page 3. 36 Tab 25. 37 Tab 25. postings dated giving a full citation to a book edited by and providing quotation marks for a large block of text quoted from and distinguishing the text from 38 Tab 25, posting dated 39 Tab 25, posting dated 40 Tab 25, posting dated 41 Tab 9, Source F. 42 Tab 10, Source G, H, and J. 43 funded by the and operated by The whose site was copied into Proposal 1, is located at 4 The subject stated that the source of the text for passages F, G, H, and J was a article44and that the article must have copied from the sources OIG identified.45 He also stated that the citations must have been omitted when he was rearranging the text of the proposal. The inadvertent omission of the citations during the editing process was plausible given that the subject included the article in the list of references at the end of the proposal. The proposal contained no citations to that article in the proposal text. The subject did not have his original copy of the article but provided a copy of the article that he found online prior to OIG's interview.46 OIG also obtained a copy via Lexis-Nexis and found none of the copied text in the article.47 OIG could not rule out that the copied text appeared in a sidebar to the article. However, the ultimate source of the text appeared to be the sources OIG identified. Whether the subject copied directly from the sources OIG identified or from a source that copied and apparently plagiarized those sources, the subject did copy the material from a source and failed to provide proper attribution. Passage K was a list of competencies that the institution's faculty would develop as part of the proposed This list was copied from the training materials of the vendor4' who would provide the training course. The vendor has an established certified training program at the subject's institution and Co-PI 1 manages that program.50 As part of that arrangement, the vender and the institution have a licensing agreement, of which Co-PI 1 provided only a part to OIG despite requests for a complete copy. The subject and Co-PI 1 put forward the excerpt of the licensing agreement as evidence of the vendor's permission to use the copied text." However, OIG interpreted the evidence provided as giving the institution permission to copy the course materials for course use.52 OIG noted that in a preceding section of the agreement,53the vendor retained rights for product identification, strongly suggesting that the vendor would not give permission for its materials to be used uncited. The subject made efforts to obtain permission from the vendor to use the text after the investigation began.54 The subject reported the vendor's response to OIG in an email that confirmed OIG's interpretation of the agreement.55 OIG therefore concluded that the subject did not have permission to use the copied text in passage K. For the reasons stated above, OIG concluded that the subject copied the source material into Proposal 1 without giving proper credit. 44 Tab 2 1, 45 Tab 13, page 3. 46 Tab 22, page 2. 47 ~ a 21. b 48 Tab 12, Source K. 49 50 Tab 15, page 1. 51 Tab 16, page 3. 5Z Tab 16, page 3, Section 8.C. 53 Tab 16, page 3, Section 6.C. 54 Tab 22, page 2-3. SS Tab 24. Text copied but not distinguished. This category includes two passages (A and D) identified in Proposal 2 as well as two passages fiom Proposal 1 (E and I). All four of the passages appeared in the subject's description of the need for the project. Passage A is fourteen lines of proposal text immediately following the heading "Need for the Almost all of the fourteen lines of this passage are copied verbatim fiom the text found in the ."~~ The subject appears to have made one minor edit to connect the fourth sentence to the proposed work and the penultimate sentence to add "chemists" to the list of professions utilizing mathematics. Although the subject included a citation, it does not reasonably lead the reader to the source document nor is the copied text distinguished in any manner fi-om the subject's original text. Furthermore, passage A is the introductory paragraph of this section of the proposal containing only three lines of the subject's original text at the end of the passage. OIG determined this to be the use of another's words without appropriate credit. Also under the heading of "Need for the Project," Passage D was approximately three lines of copied text taken from a 58 The subject copied the first sentence of this two-sentence passage verbatim fiom the white paper. The subject rearranged the phrases of the source material to create the second sentence. The subject provided a citation only after the second sentence but did not provide a corresponding entry in the references section of the proposal. Thus, the reader has no means of finding the source document. OIG determined this to be a use of another's words without appropriate credit. Passage E was a ~ o x i m a t e l ytwo lines of text substantially similar to text in a trade association report. The subject provided a citation to the trade association report. This section arguably suggests to the reader that the information comes from the cited source because of the introductory clause "One estimate was . . . ."60 However, the clauses copied appeared in the same order as in the source document and the word "they" was retained suggesting cut-and-paste copying instead of paraphrasing.61 Although of minor consequence when considered in isolation, passage E appeared consistent with the pattern of copying in both proposals. As such, OIG determined this to be a use of another's words without appropriate credit. Passage I consisted of approximately three lines of copied text.62 As in Passage E, the subject copied one sentence verbatim and made de minimis deletions to the other 56 Tab 4. " Tab 4, pages 1-2. '' Tab 7. 59 Tab 8. 6D Tab 8, project description, page 1. 6' Tab 8, project description, page 1. 62 Tab 11, Source I. keeping the clauses in the same order. The subject did cite this passage to the correct source but did not use any means to distinguish the copied text from his original text. As with passage E, Passage I appeared consistent with the pattern of copying exhibited in the two proposals. Therefore, OIG found this to be a use of another's words without giving appropriate credit. Incorrect Citation. The subject provided citations for passages B and C, but those citations did not accurately reflect the origin of the material copied. Furthermore, the subject did not distinguish the text from his own. The subject copied passage B from an article on an educational software development company's ~ e b s i t e The . ~ ~article described a study funded by the Department of Education. The subject copied four lines of text verbatim and cited the Department of Education rather than the article describing the study.64 Thus, OIG concluded that the subject copied the text without proper credit for the source of the text in passage B. The subject co ied passage C fiom a website reviewing and marketing the books of a particular author! The copied text describes one of the author's books. The subject cited to the book itself as the source of the material without quotation marks when the source text was actually a review of the book.66 While the text may paraphrase the content of the book, someone other than the subject and presumably other than the author of the book authored the text. The subject also provided a citation to a second source67in Proposal 2 for part of the text that OIG identified as copied from the website. Thus, the subject did not provide proper credit for the source of the text in passage C. The Act The subject admitted that he copied the four pages of text into the NSF proposals in both his written statement^^^ and his interview with OIG staff.69 The subject correctly pointed out that the proposals contained citations to some of the questioned text, although he did not distinguish that text (e.g., with quotation marks, block indentation) as he should have.70 He also wrote that he paraphrased some of the questioned text, but that he now believes that he did not paraphrase the text s ~ f f i c i e n t l ~The . ~ ' subject also noted that the source of some of the text was a separate newspaper article that he believes 63 Tab 5, Source B. 64 Tab 2, project description, page 2. 65 Tab 6, Source C, from website for author 66 Tab 2, project description, page 2. 67 b page 1; and Tab 14, page 1. ~ a 13, 69 Tab 22, page 1. 70 Tab 13, pages 1-3. 71 Tab 13, page 2. plagiarized the source documents identified by OIG?* This fact may be true, however, whether the subject copied from the original source or the newspaper article, he still used that verbatim text without the correct citation or attribution to the source he used. Intent The subject admitted that he was rushed to complete the proposals and embarrassed that he did not catch the copied materials before the proposals were ~ubrnitted?~Postings by the subject to an online public discussion group for grant writers also indicated that the subject routinely works on proposals up to the submission deadline.74 In the discussion thread, the subject wrote that he periodically takes refresher courses "to eliminate bad habits" and "unnecessary shortcuts.'775These statements evidenced the subject's awareness that he sometimes "tends" to take shortcuts and needs periodic refresher training to correct that behavior. Therefore, the subject was aware that he was sometimes prone to shortcuts. The subject conceded that the time pressure was not an acceptable excuse.76 The cut-and-paste nature of the copying with minor editing also evidences intent on the part of the subject to copy the text into the proposals. The meager efforts at citation demonstrated the subject knew that the material was not his original material. This was not a case of ignorance regarding proper citation to source material. Postings by the subject to an informal online public discussion group for grant writers evidence his knowledge that copied text should be distinguished from his own original text.77 The subject also demonstrated greater care in the informal posting, roviding a full formal citation in one instance78and means of offsetting text in otherse9 than in the two NSF proposals he authored. Thus, OIG concludes that the subject knew that when copying text from a source document both a citation and a means of distinguishing the copied text were necessary. OIG found additional evidence of intent particularly with regard to the "Need for the Project" section of Proposal 2. The subject copied approximately one page of this section from other sources (passages A, B, and C), the largest single passage (A) consisting of a paragraph fourteen lines long8' The subject did not precede the passage 72 Tab 13, page 2. 73 Tab 13, page 1; and Tab 22, page 2. online discussion thread for grant writers. See messages dated )giving a full citation to a book edited by( " Tab 2, project description, page 2. with any original text nor did he make any effort to paraphrase the text into his own language. It is not plausible to believe that the subject carelessly and unknowingly cut and pasted extensive amounts of text into his proposal. Therefore, OIG concludes that the subject acted knowingly in copying material fiom the source documents into the proposals and failing to provide appropriate attribution, which includes sufficient citation to lead the reader to the original material and a means of distinguishing the copied text fi-om his own original work. Standard o f Proof A preponderance of the evidence shows that the subject copied the materials and failed to provide proper attribution to the sources he used in preparing the NSF proposals. Thus, OIG concludes that the subject committed research misconduct. OIG's Recommended Disposition Seriousness The subject's role as the Director of Grants at the institution elevates the seriousness of his actions. In that position, he serves as the conduit through which NSF and other Federal institutions receive proposals from the institution. In addition, he explained that he routinely assists the faculty in writing proposals when faculty members are too busy to do so for themselves.*' It is clear that he fills roles normally segregated to different parties in the proposal preparation process at other institutions. Thus, there is a greater risk that proposals authored by the subject for submission to NSF could contain plagiarized material. However, several addition relevant circumstances surrounding this particular case also affect OIG's determination of the seriousness of the subject's actions. Those circumstances include: 1. The subject's primary academic training is in the humanities, but he has not demonstrated proper scholarship or attribution in accord with that training. 2. In contrast to past NSF plagiarism cases, the subject provided some level of citation to many of the passages of copied text, but failed to offset the copied text to distinguish his text fiom the copied text. 3. The formatting of the proposals tends to exaggerate the amount of text copied (4 pages) because of double spacing and wide margins. Furthermore, approximately one page of text is attributable to lists of short statements rather than full lines descriptive text. Tab 13, page 2. 4. The subject had a misunderstanding of a complex licensing agreement involving intellectual property rights that led him to believe that he and Co-PI 1 had permission to use some text without citation. 5. The subject has submitted other NSF proposals on behalf of others at the institution but in those cases the he did not author those proposals. Our analysis of those proposals found no evidence of plagiarized material. 6. Although writing funded NSF proposals would have be an accomplishment to add to his grant writing accolades, the subject did not write the proposals for personal gain. The subject does not charge fees for writing proposals, successful or otherwise. He is also not a faculty member with concerns of tenure and an active research program. Furthermore based on the written statements of the Co-PIS and our interview with the subject, we conclude that the subject's motivation was only to assist colleagues who were otherwise too busy to write their own proposals. 7. Throughout our investigation the subject fully cooperated with the OIG investigators and accepted full responsibility for the copied text, asking that any NSF action be directed solely at him and not his institution. In light of these aggravating and mitigating circumstances, we conclude that subject's actions were serious because of his position at the institution, but that other relevant circumstances support attenuated action by NSF, as compared to similar past cases. Our recommendations, below, reflect this conclusion. Degree o fIntent The evidence indicated that subject acted knowingly under pressing deadlines. Based on the unique circumstances of this case as described above, OIG concluded that the subject's intent was knowing but not motivated by self-interest as found with subjects in other plagiarism cases adjudicated by NSF. Pattern Although two NSF proposals were involved in this case, OIG found no evidence of copying in the other NSF proposals submitted through the subject's office at the institution. OIG notes that the subject also analyzed another NSF proposal he authored and provided OIG with the source material cited in that proposal. OIG's analysis concurred with the subject's, concluding that the third proposal did not appear to have any plagiarized material. OIG concluded that there is insufficient evidence to support an extensive pattern of plagiarism by the subject. Im-pact on the research record OIG identified no impact on the research record in this case. Neither Proposal 1 nor Proposal 2 received h d i n g from NSF. Recommendation Based on its investigation, OIG recommends that NSF: send a letter of reprimand to the subject informing him that NSF has made a finding of research misconduct; require the subject to certify the completion of a course on ethics in scientific research before submitting any proposals to NSF on which he is a principal investigator (PI), co-principal investigator (Co-PI), or otherwise contributes as an author; and require the subject to certify that proposals he submits as PI, Co-PI, or otherwise contributes as an author, to NSF do not contain plagiarized material for 1 year commencing with the date of NSFYsfinding of research misconduct. The Subiect's Responses to the Draft Investigation ~ e p o r t ~ ~ The subject responded by letter noting his acceptance of our conclusions and willingness to abide by our recommendations, including training in the ethics of scientific research. Therefore, we have made no changes to the report. 82 Tab 27, the subject's response to the OIG Draft Investigation Report.
Published by the National Science Foundation, Office of Inspector General on 2006-02-15.
Below is a raw (and likely hideous) rendition of the original report. (PDF)