NATIONAL SCIENCE FOUNDATION
OFFICE OF INSPECTOR GENERAL
OFFICE OF INVESTIGATIONS
CLOSEOUT MEMORANDUM
Case Number: A11100067 Page 1 of 1
Closeout
We conducted in inquiry into an allegation that two NSF Proposals 1 with a common PI
(Subject1 2 ) and co-PI (Subject23) contained plagiarized text. In their inquiry responses, both
subjects agreed that that the responsibility lay with Subject!. Subjectl acknowledged
inappropriate attribution in the proposals. We referred the matter to the University4 , which found
that she compiled the proposals by assembling notes from her own and others' writing. She acted
recklessly in not ensuring that verbatim text was properly demarcated and cited, a significant
departure from expected community standards and therefore committed research misconduct. We
agreed with the University's assessment.
We recommended actions to protect the federal interest and the Deputy Director took
actions based on our report.
This memo, the attached Report oflnvestigation, and the Deputy Director's decision
letter constitute the case closeout. Accordingly, this case is closed with no further action taken.
NSF OIG Form 2 (11102)
SENSITIVE SENSITIVE
National Science Foundation
Office of Inspector General
Report of Investigation
Case Number A11100067
February 18, 2014
This Report of Investigation is provided to you
FOR OFFICIAL USE ONLY.
It contains protected personal information, the unauthorized disclosure of which may result in
personal criminal liability under the Privacy Act, 5 U.S.C. § 552a. This report may be further
disclosed within NSF only to individuals who must have knowledge of its contents to
facilitate NSF's assessment and resolution of this matter. This report may be disclosed
outside NSF only under the Freedom of Information and Privacy A,cts, 5 U.S.C, §§ 552 &
552a. Please take appropriate precautions handling this report of investigation.
NSF OIG Form 22b (1113)
SENSITIVE SENSITIVE
Executive Summary
Allegation: Plagiarism in an NSF proposaL
OIG Inquiry: OIG identified 12 sources from which approximately 58 lines of text were
copied into two NSF proposals. Both proposals shared the PI (Subject!) and
a co-PI (Subject2). During our inquiry, Subject! took responsibility for all of
the copying. OIG referred investigation of only Subject! 's actions.
University The University concluded that Subjectl recklessly plagiarized and, as
Investigation and sanction, placed a letter of repnmand in the Subject's personnel file.
Action:
OIG's Assessment: • The Act: Subjectl plagiarized 58 lines from 12 sources into 2 NSF
Proposals.
• Intent: Subject! acted recklessly.
• Significant Departure: Subject} 's actions are a significant departure
from the accepted practices of the research community.
• Standard of Proof: The preponderance ofthe evidence supports the
conclusion regarding the act and intent, and therefore a finding of
research misconduct.
OIG • Send Subject I a letter of reprimand notifying her that NSF has made a
Recommendation: fmding of research misconduct.
• Require Subject!_ to certify completion of an RCR course.
• Require Subject! to submit certifications for 1 year.
• Bar Subjectl from participating as a reviewer, advisor, or consultant for
NSF for a period ofl year.
1
SENSITIVE SENSITIVE
OIG's Inquiry
Our inquiry into plagiarism in an NSF Proposal (Proposal I) found 40 lines of copied
1
text, as well as 1 figure and 1 embedded reference, from 9 sources. We reviewed 5 other
3
proposals and found 18 lines of copied text in another NSF Proposal (Proposal2) from 3
sources. Because the two proposals shared two authors in common, the PI (Subjectlt and a co-
PI (Subject2) 5 , we sent inquiry letters 6 to only those two authors. In each of their replies, 7 both
subjects agreed that the responsibility lay with Subject!. In Subject I 's reply, she stated that most
portions of text were cited, albeit not "properly'' 8, though we found that the citations provided
9
did not contain the text in question. We wrote to Subject! again to ask for clarification, but in
her response to the second letter, 10 she could not explain why the passages of text had incorrect
citations.
We concluded that there was sufficient evidence to proceed to an investigation of
Subject! 's actions. However, we determined that allegations against Subject2 were
unsubstantiated and we inake no recommendations about Subject2 in this report.
The University's Investigation
12
We referred an investigation to Subject! 's university 11 (University), which produced an
Investigation Report. 13 .1 4 .
. . The University sequestered copies of Subject! 'shard drives and sent her a letter, inviting
15
her comment on the allegation. Subject! responded to the University's letter to reiterate that
17
her actions were not intentional. 16 Consistent with its policy, the University appointed an
investigation committee (Committee) to investigate the allegation and sent her a notification of
investigation. 18 She responded to this letter as well, expressing contrition for her actions, as well
(Status: Declined).
, co
6
Tab 3, Inquiry Letters.
7
Tab 4, Responses to Inquiry Letters.
8
See Tab 4, Subject! 's Response, pages 2-4.
9
II············
Tab 5, Second Letter from OIG.
10
Tab 6, Response to Second Letter from OIG.
12
Tab 7 contains the referral letter.
13
Tab 8, The University's Investigation Report.
14
Tab 9, Attachments to the University Report
15
Tab 9, Attachment 1, Letter ofFebruary7, 2012 from RIO to Subject!, page 20 ofthe PDF.
16
Tab 9, Attachment 1, Email letter of February 28,2012 from Subject] to RIO, page 23 of PDF.
17
See Tab 10, Integrity Policy
18
Tab 9, Attachment 1, Email letter of Aprill2, 2012 from RIO to Subject!, pages 26-28 of PDF.
2
SENSITIVE SENSITIVE
as stating that her decision to leave the University had been made the year prior before -she had
19
received the Inquiry Letter from NSF-OIG.
The Committee determined that an interview with Subjectl would not be necessary and
Subject I declined to invoke her right to demand one?0 The Committee reviewed other
documents that Subjectl had co-authored, and determined only one, another NSF Pro osal
ropos , a een written primarily by Subject!. Because the iThenticate analysis of that
proposal indicated that the document did not contain plagiarized text, the Committee concluded
that there was no pattern ofplagiarism. 22 ·
The Report stated Subject! "apparently disregarded the well established rules concerning·
the proper use of another's words and the attribution of copied texts to their original sources."23
The Cortnilittee detem1ined, based 011 tl1e preponderance of the evidence, that Subjectl recklessly
24
plagiarized material into Proposal I and Proposal2. They recommended a letter of reprimand be
placed in Subject I 's file.
The Deciding OfficiarZ 5 concurred with their findings and imposed the above sanction.
OIG's Assessment
We assessed the Report for accuracy and completeness and whether the University ·
followed reasonable procedures in its investigation. 26 We found that the general procedures were
reasonable and the Uniyersity provided an acceptable evidentiary record. Because the
documentation and review details for Proposal3 were not included with the University's Report,
we opted to review Proposal3 ourselves. The copied text that we found was de minimis. We
accepted the University's report in full.
A finding of misconduct requires that: (1) there be a significant departure from accepted
practices of the relevant research community, (2) the research misconduct be committed
intentionally, or knowingly, or recklessly, and (3) the allegation be proven by a preponderance of
the evidence. 27 · · ,
23
24
~
26
27
Report, p. 4.
Tab 8, University Report, p. 4.
Tab 8, University Report, p. 4.
45 C.F.R. §689.9(a).
45 C.F.R. 689.2(c).
...........
3
SENSITIVE SENSITIVE
The Act
Subjectl admitted her responsibility for the unattributed text in Proposall and Proposal2.
Subject I 's unattributed copying is consistent with NSF's definition of plagiarism28 and is a
departure from the accepted practices of the research community.
We agree with the Committee's assessment that Subjectl 's actions went above "merely
being careless, but are more properly categorized as being reckless in nature, since proper
29
checking of citations and appropriate attributions were not provided." In assembling notes from
her own and others' writing, without the due diligence that NSF requires 30 for citing and quoting
the appropriate source texts, Subject! acted in a reckless manner.
Standard o{Proo{
The preponderance of the evidence supports that Subjectl recklessly plagiarized and that
her actions were a significant departure from the accepted practices of the relevant research
community.
We therefore conclude that Subject! 's actions constitute research misconduct.
Subjectl's Response to OIG's Draft Investigation Report
. 31
The Subject responded to tell us that she had no comments to add to our report.
OIG's Recommended Disposition
When deciding what appropriate action to take upon a fmdirig of misconduct, NSF must
consider:
(1) How serious the misconduct was; (2) The degree to which the
misconduct was knowing, intentional, or reckless; (3) Whether it
was an isolated event or part of a pattern; (4) Whether it had a
significant impact on the research record, research subjects, other
researchers, institutions or the public welfare; and (5) Other
relevant circumstances. 32 ·
Seriousness
28
45 C.F.R. 689.1(a)(3)
29
Tab 8, University Report, p. 4-5.
30
NSF Grant Proposal Guide section 1.0.3.
31
Tab II.
32
45 C.F.R. 689.3(b).
4
SENSITIVE SENSITIVE
The amount of text copied by Subjectl was less than many cases our office has
investigated and was not contiguous in either proposal. The level of seriousness is low.
Pattern and Impact on the Research Record
We reviewed the Omvers1ty's assessment of pattern, supplementing it with our own
review of Proposal3; we concur with their conclusion that there is no pattern of plagiarism.
Subject! 's act has no effect on the published research record.
Other Mitigating Factors
A.:-: """' .. -...n~ -~-.f: ,..........,...., ,..!"\!"'.O!""~~o.~t "!""!.~ "'!"'.Df".E""Y'n~P'!"'!.f'i-:!"tin~C'I ·n7P r:li1C'In +n.Alr ~nf-A i"A'I"\C'1H.::::..1"'-:r.i-~ ..,
r-1..~ J."'-'"-'UJ._l_.lJ.J..J..V.l..l~f...oL. ... .l.V.L~o..)' "'""" U..i.JV i..VV£..._ .li..ii..V VV.i..ii.J.i'-i.'-'.i.U..L.~o.i.i_
.....
a .1-'a.l.l Ul. UUJ. d,:),:,O\.,;L).:)1J.1"-'U.. t. a..i.LU.
Subjectl 's background and position; she is neither a researcher nor a faculty member.
Recommendations
Based on the evidence, OIG recommends that NSF:
• Send Subject 1 a letter of reprimand notifying her that NSF has made a finding of ·
research misconduct. 33 ·
• Require Subjectl to certify to the Assistant Inspector General for Investigations
(AlGI) completion of a responsible conduct of research training program and provide
documentation of the program's content within 1 year ofNSF's fmding. 34
. For a period of 1 year as ofthe date ofNSF's fmding:
• Bar Subject I from participating as a peer reviewer, advisor, or consultant for NSF. 35 ·
• Require for each document (proposal, report, etc.) to which Subjectl contributes for
submission to NSF (directly or through his institution),
o Subject I to submit a contemporaneous certification to the AlGI that the
document does not contain plagiarism, falsification, or fabrication. 36
o Subject! to submit contemporaneous assurances from a responsible official of
her employer to the AlGI that the document does not contain plagiarism,
falsification, or fabrication. 37 ·
33
A Group] action 45 C.FK 689.3(a)(J)(i).
34
This action is similar to Group I actions 45 C.F.R. 689.3(a)(I).
35
A Group III action 45 C.F.R. 689.3(a)(3)(ii).
36
This action is similar to 45 C.F.R. 689.3(a)(l)(iii).
37
A Group I action 45 C.F.R. 689.3(a)(l)(iii).
5
NATIONAL SCIENCE FOUNDATION
4201 WILSON BOULEVARD
ARLINGTON, VIRGINIA 22230
JUL n81014
OFFICE OF THE
DEPUTY D·IRECTOR
CERTIFIED MAIL -RETURN RECEIPT REQUESTED
Re: Notice ofResearch Misconduct Determi11ation
Dear-:
("University"), you
served as the Principal Investigator (PI) on two proposals that were submitted to the National
Science Fotmdation ("NSF") Division of Computer and Network Systems. As documented in the
attached InveStigative Report prepared by NSF's Office of Inspector General ("OIG''), the
proposals contained 58 lines ofplagiarizedmaterial.
Research Misconduct and Proposed Sanctions
Under NSF's regulations, "research misconduct" is defined as ''fabrication, falsification, or
plagiarism in proposing or petforming research funded by NSF .... " 45 CFR § 689.l(a). NSF
defines "plagiarism'; as the "appropriation ofanother person's ideas, processes, results or words
without giving appropriate credit." 45 CFR § 689.1 (ll-)(3).
A finding of research misconduct requires that:
(1) There be a significant departure from accepted practices of the relevant research
commUnity; and
(2) The research misconduct be cominitted intentionally, or knowingly, or recklessly; and
(3) The allegation be proven by a preponderance of evidence.
45 CFR § 689.2(c)
Page2
Your admission that the proposals contain copied material permits me to conclude that yol,it
actions meet the applicable <fefm.ition of plagiarism, as set forth -in NSf's regulations.
Pursuap.t toNSF's regulations, the Foundation must also determine whether to make a finding of
research misconduct based on a preponderance ofthe eVidence-45 CFR § 689.2(c). After
reviewing theOIG Investigative Report and your admission of plagiarism, NSF has d,etermined
that, based on a preponderance of the evidence, the plagiarism was committed recklessly and
constituted a significailt departure from accepted practices of the relevant research qotnmunity. I
ar.iJ:.~· therefOre, issuing a fmding of researCh misconduct against .you.
NSF's regulations establish three categories ofaction:S (Group I, II, and III) that can be taken in
response to a finding of misconduct. 45 CFR § 689.3(a). Group I actions include iss11ingaJetter
of reprimand; conditioning awards on prior approval ofparticuJar activities from NSF; 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 iridude award
suspension or restrictions on designated activities ot expenditures; reqt1iring .special reviews of
request$ for funding; and requiring corre9tion to the research record. 45 CFR § 689.3(a)(2).
Grol,ip ill actions 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 § 6893{a)(3).
In determii:J.ing the severity of the sanction to impose for research misconduct, I have considered
the s.edousness of the misconduct; my determination that it was committed recklessly; the fact
that the misconduct had no impact on the 1;esearch record; and the fact that the misconduct was
an jso1ated incident. I have also .considered other relevant circumstances. See 45 CFR § 689 .3(b).
Based on the foregoing, I am imposing the following acti()n on you:
• You are required to complete a comprehensive responsible cpnductofresearch training
course byJuly 1,2015, and provide documentation ofthe program's content. The
instruction should bein an interactive forinat (e.g., an instructor-led course, workshop,
etc.) and should include adiSClJSSion of plagiarism.
All training documentation should be submitted in writing to NSF's Office of the Inspector
General, Associate Inspector General for Investigations, 4201 Wilson Boulevard, Arlington,
Vitgiriia 22230.
Appeal Procedures for fmding of Research Misconduct
Under NSF's regulations, you have 30 paysafteueceipt of this letter to submit an appeal of this
firtding, inwriting, to theDirector of the Foundation. 45 CFR§ 689.10(a). Any appeal should be
addressed to the Director at the National Science Foundation, 4201 Wils:onBoulevard,
Page 3
Arlington, Virginia 22230. If we do not receive your appeal within the 30-day period, the
decision on the finding of researchmisconductwill become fwaLFor your information, we are
attaching a copy of the applicable regulations.
Should you have any questions about the foregoing, please c o n t a c t - , Assistant
General Counsel, at (703) 2 9 • •
Sincerely,
Cora B. Marrett
Deputy Director
Enclosures:
Investigative Report
Nonprocurement Debarment Regulations
FAR Regulations
45 CPR Pait689
Plagiarism (Verbatim)
Published by the National Science Foundation, Office of Inspector General on 2014-09-24.
Below is a raw (and likely hideous) rendition of the original report. (PDF)