oversight

Plagiarism (Verbatim)

Published by the National Science Foundation, Office of Inspector General on 2014-10-23.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                 NATIONAL SCIENCE FOUNDATION
                                                  OFFICE OF INSPECTOR GENERAL
                                                    OFFICE OF INVESTIGATIONS

                                            CLOSEOUT MEMORANDUM

 Case Number: Al2030013                                                                     Page 1 of 1



                 NSF OIG received an allegation that a PI 1 and two Co-Pis2 submitted an NSF Proposal3
         containing plagiarism. Our inquiry determined that the PI was responsible for the plagiarism. We
                                                4
         referred the matter to his University.

                 The University's investigation concluded that the PI did not himself commit the
         plagiarism found and that the acts were not a significant departure from accepted practices of
         long term collaborators. The Committee recommended actions to protect the University's
         interests.

                 We assessed the University's Report and did not find it to be either fully accurate or
         complete. We therefore conducted our own investigation, which concluded, based on a
         preponderance of the evidence, that the PI recklessly plagiarized material in one NSF proposal,
         deemed a significant departure from accepted practice. We recommended actions to be taken to
         protect the federal interest. The Deputy Director concurred with our recommendations.

                 This memo, the attached Report of Investigation, and letter from the Deputy Director
         constitute the case closeout. Accordingly, this case is closed.




NSF OIG Form 2 (11/02)
SENSITIVE                                                                              SENSITIVE




      National Science Foundation
        Office of Inspector General




                  Report of Investigation
                 Case Number A12030013
                             March 27, 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 Acts, 5 U.S.C. §§ 552 &
 552a. Please take appropriate precautions handling this report of investigation.

                                                                             NSF OIG Form 22b (1/13)
 SENSITIVE                                                                           SENSITIVE



                                    Executive Summary

Allegation:     Plagiarism.

OIG Inquiry:    OIG identified four sources from which 67lines, four figures, and 22 embedded
                references were copied into one NSF Proposal. Based on responses to our inquiry
                letters, we modified our assessment to identified 45 lines and 22 embedded
                references copied froni one source into the Proposal and determined the Subject
                was responsible. OIG referred the investigation to the Subject's institution.

University
Investigation
and Action:     The University found 12 instances of plagiarism· in one publication and six
                proposals. Despite stating that the Subject recklessly committed "what is viewed
                by the general research community as plagiarism," it found that the Subject did
                not himself commit plagiarism and that the acts were not a significant departure
                from accepted practices of long term collaborators.

                The Committee recommended that the Subject complete RCR training;
                implement a requirement that those he works with complete RCR and provide
                proof of implementation; implement a requirement that contributors certify "that
                all standards for authorship and publication are regarded in their written
                contributions;" and review for five years all of his publications and proposals
                with plagiarism detection software. The University has not sent the Subject an
                official letter requiring adherence to these recommendations, although it
                concurred with the recommendations.

OIG
Assessment:
                •   The Act: Subject plagiarized 45 lines and 22 embedded references into one
                    NSF proposal.
                •   Intent: Subject acted recklessly.
                •   Standard of Proof: A preponderance of evidence supports the conclusion
                    that the Subject committed plagiarism.
                •   Significant Departure: The Subject's plagiarism represents a significant
                    departure from accepted practices.
                •   Pattern: None

OIG
Recommends:
                •   Make a finding of research misconduct against the Subject
                •   Send the Subject a letter of reprimand
                •   Require certifications from the Subject for a period Of one year
                •   Require certification of attending a comprehensive responsible conduct of
                    research training class within one year




                                              1
    SENSITIVE                                                                                   SENSITIVE


                                                    OIG's Inquiry

       OIG conducted an inquiry into an allegation that an NSF proposal (Proposal 1) contained
copied text. We reviewed the Proposal and found, as illustrated below, 67 lines, three figures, and
22 embedded references copied from four sources: 2

             Source                           Proposal
             A (article)                      45 lines and 22 embedded references
             B (article)                      12lines and 3 figures/captions
             c (article)                      3.5 lines and 1 figure/caption
             D (workshop abstract)            6.5 lines
             Total                            67 lines, 4 figures, and 22 embedded references

Sources B, C, and D were seemingly authored by individuals with ties to the Proposal, but who
were not acknowledged as Proposal authors. Although the Proposal included the reference for
Source A, it was not clearly linked to the text that was copied verbatim without demarcation, and
refer~nces included in the text from Source A text were used extensively in the Proposal.

                                                                            4
        We contacted the Proposal's PI (Subject)3 and Co-Pis (Co-PI1 and Co-PI2 5) regarding the
allegations6 and received separate responses from each. 7 The responses confl11Iled that
collaborators authored Sources B, C, and D and acknowledged that Source A was inadequately
cited. The responses also attributed the use of text from Source A to the Subject, who explained:

                  Ideas from multiple sources were collected to serve as background for
                  the initial version of the proposal. Source A was used initially as a
                  place holder with modifications to be made after review. Later while
                  putting together this instrumentation proposal I inadvertently
                  overlooked the imbedded mistake. Clearly this was an oversight since
                  within the write-up, reference is given to the same author as part of
                  our review. 8

Based on the responses, we concluded there was sufficient evidence to proceed to an investigation
focusing only on Source A and limited to the Subject.




                                                                     (Awarded).
2
    Tab 2.
3




6
  Tab 3.
7
  Tab 4.
8
  Tab 4, Response 1, pg 2. All quotations herein are sic.


                                                            2
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                                                University Investigation

.        Consistent with our Rolicy, we referred the investigation to the University. 9 The University,
  consistent with its policies, 1 convened a Committee, which produced a Report. 11 The Committee
  found that "The evidence proves that text from original sources was either copied verbatim or
  inappropriately paraphrased in publications and grant proposals for which [the Subject] served as
, co-author or principal investigator." 12 It said "[the Subject] did recklessly, yet unintentionally
  commit what is viewed by the general research community as plagiarism," due to a "lack of
  oversight, education, and monitoring." 13 However, it determined the Subject himself did not
  commit plagiarism 14 because "There was no clear pattern that established [the Subject] as the sole
  author of any of the publications that were plagiarized nor that he personally had plagiarized. " 15

            The Committee's investigation examine(! one publication and six federally-funqed grant
    proposals the Subject authored or co-authored, including the Proposal. 16 The Committee focused
    primarily on proposals because they "were deemed most reliable in determining if [the Subject]
    personally demonstrated a pattern of plagiarism and to determine any intent in doing so. " 17 The
    Committee considered material plagiarized "If it was determined that verbatim text from the
    [Subject's] documents matched text from other sources within areas such as the introduction,
    abstract, or results without proper citation or inappropriate paraphrasing.... " 18 and "there was no
    relationship between the original author and [the Subject] or his research centers." 19 The
    Committee concluded there were 12 such instances of plagiarism? 0

              The Subject attributed plagiarism in the documents to there being "a joint effort." 21 He
    said:

                      I used information and the write-up that was collected from the
                      Center team. I had it there on my system as a placeholder....
                      Someone sent it to me or gave it to me on a flash drive, during a:
                      meeting or something and I forgot to cite it more clearly and
                           '                   22
                      remove the placeholder.




    9
     -        Tab 5 contains the referral letter.
    10
       Tab 6.
    11
       Tab 7 contains the initial documents the University provided; Tab 8 includes subsequent documents the University
    provided in response to our requests. The Subject saw a copy of the University's draft report and provided comments
    that the Committee incorporated into its final Report.
    12
       Tab 7, pg 8-9.
    13
       Tab 7, pg 12.
    14
       Tab 7, pg 8.
    15
       Tab 7, pg 9.
    16
       Tab 7, pg 17-25. Of the six proposals, four received NSF funding and two received DOD funding.
    17
       Tab 7, pg 4.               .
    18
       Tab 7, pg 6.
    19
       Tab 7, pg 4.
    20
       Tab 7, pg 4-5. Tab 7, pg 17-25, include a chart of the Committee's plagiarism analysis.
    21
       Tab 7, pg 15.
    22
       Tab 7, pg 7.


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He said "I always told the team on so many occasions to follow the best practices and I assumed
that's so and I thought that they knew what they were doing.... I always moved ahead with the
assumption that they stand by what they have gave me.'m He added "When this [P]roposal was
written I was responding also the NSF site visit for the [ ],24 many things were going on at the
                                                                                                 26
time."25 He concluded that "The mistake took place with me not knowing there was an error."

       The Committee determined the "Plagiarism was part of a reckless pattern of copying text
                                                                                 27
from original sources without proper citation and inappropriate paraphrasing." It said that most
individuals supported by the Subject are "foreign nationals" and that "As his research organization
has grown, [the Subject]'s ability to ensure avoidance of research misconduct ... has become less
apparent in the development ofpublications."28 Specifically, "There was no structured process that
would have allowed [the Subject] to easily determine which contributor failed to follow the
standards for avoiding plagiarism or tracking original sources in the final version." 29 It concluded:

                  A reasonable, experienced scientist overseeing multiple projects
                  and developing numerous publications on a continuous basis
                  would have established a better practice to ensure accountability
                  for responsible authorship and publication to avoid plagiarism. 30

       The Committee found the Subject's actions did not constitute "a significant departure from
accepted practices oflong term collaborators,"31 but only included in the Report the "standards for
responsible authorship and publication" "in the general academic research community" and the
Subject's professional society. 32

       The Committee reported the Subject had taken two one-hour responsible conduct of research
(RCR) training sessions, which included training "to reinforce appropriate paraphrasing, discuss
mentoring, data management, and authorship and publication. "3
                                                                                                       '\

        Lastly, the Committee determined that the plagiarism did not have a significant impact on
the research community because it did not occur in the documents' results or conclusions section. 34




23
   Tab 7, pg 8.
24
   ERC. 1
25
   Tab 7, pg 8. The Subject said that the scientist who generally ensures completion of final edits experienced a
personal tragedy and did not conduct his customary fmal document review before submission.
u                                                                     .
   Tab 7,pg 8.
27
   Tab 7, pg 12. The Report however noted that citations to the identified solirces were often included in the reference
list "suggesting no effort to conceal the sources used" (Tab 7, pg 12).
28
   Tab 7, pg 15.
29
   Tab 7, pg 15.
30
   Tab 7, pg 12.
31
   Tab 7, pg 11.
32
   Tab 7, pg 11-12. The Report referenced the National Society of Professional Engineer's Code ofEthics.
33
   Tab 7, pg 14.
34
   Tab 7, pg 13.


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                                  University Recommendation/Adjudication

          The Committee recommended that the Subject 1) complete an RCR series; 2) implement a
 requirement that his students, co-investigators, and international collaborators complete RCR and
 provide proof of implementation; 3) implement a requirement that contributors certify "that all
 standards for authorship and publication are regarded in their written contributions;" and 4) review
 all of his publications and proposals with plagiarism detection software for five years. 35 The
 Committee also reported that, as a result of this matter, the University now examines proposals
 using plagiarism detection software before their submission to funding agencies. 36

         The University informed us that, though University administrators read the report and
 agreed with the recommendations, it has not sent the Subject an official letter requiring him to
 adhere to the recommendations. Additionally, while it intends to implement a policy regarding
 routine use of plagiarism detection software, it is currently assessing other institutions' policies on
 this matter before drafting its own. 37


                          OIG's Assessment of the University Investigation Report

         OIG invited the Subject's comments38 on the University Report. His response, 39 which
 included a letter to our office and a copy of the comments he provided to the University on its draft
 report, reiterated the assertions he made during the inquiry and investigation. He added however
 that "I will work with the University in implement a procedure that will facilitate the elimination of
 such errors in future. "40

          OIG assessed the Report for accuracy and completeness, and did not find the Report to be
· either fully accurate or complete; the Report provided contradictory findings without adequate
  explanation. Most notably, the Report stated the Subject recklessly committed "what is viewed by
  the general research community as plagiarism,"41 but did not find that the Subject committed
  plagiarism. 42 Additionally, in deciding the act was not a significant departure from accepted
  practices, the Report relied on unidentified "standards oflong term collaborators." 43 Overall, the
  Report focused less on the plagiarism in the Proposal we referred for investigation, and more on
  examining whether the Subject exhibited a pattern of plagiarism.44 For these reasons, we could not
  accept the report in its totality in lieu of conducting our own investigation.




 35
     Tab 7, pg 16.
 36
     Tab 7, pg 5.
 37
    · · · · · · · · · · · · · · · - c o n v e y e d this information in a January 10, 2014, email.
 38
     Tab 9.
 39
    .Tab 10.
 40
     Tab 10, Final Comments, pg 2.
 41
     Tab 7, pg 12.
 42
     Tab 7, pg 8.
 43
     Tab 7, pg 11-12. Note, per footnote 50 below, standards ofpractice within the Subject's research community indicate
 his actions were indeed a violation of standards of collaborators.
 44
     A pattern of misconduct has limited evidentiary use in determining whether research misconduct has occurred.


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                                                 OIG's Investigation

       Our investigation focused on the Proposal we referred to the University. We concurred with
the Committee's assessment that inclusion of Source A material constituted plagiarism45 and that
the Subject generally acted recklessly in committing "what is viewed by the general research
community as plagiarism."46 However, unlike the University, for reasons below, we concluded the
Subject committed plagiarism, which we deemed a significant departure from accepted practices.

        The Subject's statements to us and the Committee asserted that he inserted material from
Source A, which he received from unnamed others, as a placeholder with the intent to later modify47
or cite48 it. The Subjectthereby acknowledged he was personally responsible for compiling the
Proposal and had himself inserted into it placeholder material. Additionally, the Report noted both
that those providing the text were primarily "foreign nationals" and that the Subject had "no
structured process" to prevent insertion of plagiarized text. 49 Accordingly, we concluded the Subject
was himself responsible for recklessly plagiarizing material contained in the Proposal; inserting the
work of others, many of whom were non-native English speakers, in a Proposal bearing his name
without careful examination is characteristic of a reckless act of plagiarism.           ·

         We re-examined the accepted practices of the Subject's research community. We were
unable to identify the content of"accepted practices oflong term collaborators." 50 We ~so
 disagreed that the act committed was simply due to collaboratio~. Instead we concurred with the
University's ambiguous assessment that the act constituted a significant departure from general
 academic practices and the Subject's professional society's standards. To clarify and identify these
 standards, we reviewed policies of professional societies and journals with which the Subject self-
             51
 associated. Specifically, one professional society has a "Policy on Publication Ethics and
 Responsibilities" that states "Plagiarism is defined as the act of using the work of another and
 passing it off as one's own. Such behavior constitutes unethical scientific behavior and is never
               52
 acceptable. " Another professional society similarly states that it "defines plagiarism as the use or
 presentation of the ideas or words of another person from an existing source without appropriate
 acknowledgment to that source."53 Lastly, the journal of which the Subj
                                                                        54
                                                                                                                        t
-       contains a comprehensive discussion on Ethics in publishing, which states that "Plagiarism
 takes many forms, from 'passing off another's paper as the author's own paper, to copying or
 paraphrasing substantial parts of another's paper (without attribution), to claiming results from
 research conducted by others. Plagiarism in all its forms constitutes unethical publishing behavior

45
   Tab 7, pg 18. The Committee's analysis renames Source A as Source Number 1.
46
   Tab 7, pg 12.
47
   Tab 4, Response 1, pg 2.
48
   Tab 7, pg 7.
49
   Tab 7, pg 15.
50
   Tab 7, pg 11. ·
51
   Tab 7, Subject's Bio.
52
   Materials Research Society, http://www.mrs.org/publication-ethics/, viewed Jan. 17, 2014. This site also discusses
collaborations, which states that "All collaborators share some degree of responsibility for any paper they coauthor ....
Any individual unwilling or unable to accept appropriate responsibility for a paper should not be a coauthor."
53
   American Society ofMechanical Engineers, https://www.asme.org/shop/proceedings/conference-publications/ethical-
standards, viewed Jan. 17, 2014.
   iiiiiliiliiiiiiiiiliiii•
5454

                   viewed Jan.17, 2014. This page provides links to two other pages.


                                                            6
     SENSITIVE                                                                                          SENSITIVE


 and is unacceptable." 55 The journal's website also contains a discussion about ethics related to
.Plagiarism,56 which includes a webinar on Ethics and Plagiarism. 57 We conclude that the Subject
 himself violated the accepted practices of his research community by not properly acknowledging
 others' contributions in a Proposal he submitted as PI.

       Lastly, we re~reviewed theUJJiversity's evidence regarding pattern of plagiarism. We
                                                                                       58
concluded that the amount of copied material in any one document, with one exception, was
generally de minimis. We therefore did not identify a pattern of plagiarism.


                                               OIG's Assessment

        A finding of research misconduct by NSF requires (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 proved by a preponderance of
the evidence. 59

                                                      The Acts

        OIG's investigation concluded that the Subject plagiarized 45liries and 22 embedded
reference into one funded NSF proposal. We also concluded that the Subject's actions constituted a
significant departure from accepted standards within the Subject's research community.



       Based on our investigatory review, as described above, we conclude that the Subject
recklessly copied material into the Proposal.

                                                Standard o(Proo(

        OIG concludes that the Subject's actions and intent were proven based on a preponderance
of the evidence.

       OIG concludes by a preponderance of the evidence that the Subject recklessly plagiarized,
thereby committing an act of research misconduct. 60




55
   http://www.elsevier.com/joumal-authors/ethics#writing-an-article.
56
   http://www.elsevier.com/editors/perklplagiarism-detection.
57
   http://mediazone. brighttalkcorn!comm!ReedElsevier/99ed9 83 c88-25 930-225 I-2 8002.
58
   The proposal the Committee identified as P5 was the exception; two figures were copied from a source referenced in
the proposal near a statement related to the figures but not near the figures themselves.
59
    45 C.F.R. §689.2(c).
60
   45 C.F.R. part 689.


                                                          7
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                                        OIG's Recommended Disposition

       When deciding what appropriate action to take upon a finding 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. 61

                                                      Seriousness

       The Subject's actions are a violation of the standards of scholarship and the tenets of general
research ethics. Copied text serves to misrepresent one's body of knowledge, presenting reviewers
with an inaccurate representation of a proposal's respective merit.

                                                         Pattern

          Our review did not identify a pattern of plagiarism.


                                                  Recommendation

Based on the evidence, OIG recommends that NSF:
       • Send the Subject a letter of reprimand notifying him that NSF has made a finding of
           research misconduct. 62
       • Require the Subject to certify to the Assistant Inspector General for Investigations
           (AlGI) his completion of a responsible conduct of research training program and provide
           documentation of the program's content within 1 year of NSF's finding. 63 The
           instruction should be in an interactive format (e.g., an instructor-led course) and
           specifically include the topic of plagiarism.

For a period of 1 year as of the date ofNSF's finding:
       • Require for each document (proposal, report, etc.) to which the Subject contributes for
           submission to NSF (directly or through his institution),
               o the Subject to submit a contemporaneous certification to the AlGI that the
                   document does not contain plagiarism, falsification, or fabrication. 64




61
   45 C.P.R. § 689.3(b).
62
   A Group I action 45 C.F.R. 689.3(a)(l)(i).
63
   This action is similar to Group I actions 45 C.F.R. 689.3(a)(l).
64
   This action is similar to 45 C.F.R. 689.3(a)(l)(iii).


                                                             8
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                      The Subject's Response to Draft Investigation Report

        We provided the Subject with a copy of our draft report and attachments for comment. He
asked th~lt_we c1;;ujfy the recommendation pertaining to certifications he w9uld provide for each
document submitted to NSF. Specifically, he was concerned about certifying a voluminous report
he and directors from other institutional ~enters submit on behalf of the NSF award, but to which he
only minimally contributes. In response, we agree that his certification on such a document is
limited to the portion he himself authored.




                                                  9
                                  NATIONAL SCIENCE FOUNDATION
                                       4201 WILSON BOULEVARD
                                      ARLINGTON, VIRGINIA 22230




                                                                              SEP 0Z 70111
      OFfiCE OF THE
       DIRECTOR




CERTIFIED MAIL -RETURN RECEIPT REQUESTED




       Re:      Notice of Proposed Research Misconduct Determination


Dear D r . -




you served as the Principal Investigator on
documented in the attached Investigative Report prepared by NSF's Office oflnspector General
(''OIG"), the proposal contained 45 lines and 22 embedded references of plagiarized material.

Reseal·ch Misconduct and Proposed Sanctions

Under NSF's regulations, "research misconducf' is defined as "fabrication, falsification, or
plagiarism in proposing or perfmming research funded by NSF ... " 45 CFR § 689.1(a). NSF
defines "plagiarism" as the "appropriation of another person's ideas, processes, results or words
without giving appropriate credit." 45 CFR § 689.1(a)(3).

A finding of research misconduct requires that:

       (1) 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 § 689.2(c)
                                                                                              Page2


You acknowledged that you were personally responsible for compiling the Proposal and
inserting the material at issue. The plagiarized material came from a single source document, and
while the proposal included a reference to the source document, it was not clearly linked to the
text that was copied verbatim without demarcation, and references included in the text from the
source document were used extensively in the Proposal. The facts as described in the OIG report
permit me to copdude that yoUl' actions meet the applicable definition of plagiarism, as set f01th
in NSF's regulations.

Pmsuant to NSF's regulations, the Foundation must also determine whether to make a finding of
research misconduct based on a preponderance of the evidence. 45 CFR § 689 .2(c). After
reviewing the OIG Investigative Report, NSF I1as determined that, based on a preponderance of
the evidence, the plagiarism was committed recklessly and constituted a significant departure
fiom 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, II, and III) 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 of particular activities from NSF; requiring
that an. institutional representative certify as to the accuracy of reports or certifications of
compliance with pmticular requirements. 45 CFR § 689J(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 CPR§ 689.3(a)(2).
Group III 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 § 689.3(a)(3).

In detennining the severity of the sanction to impose for research misconduct, I have c.onsidered
the seriousness of the misconduct; my determination that it was committed recklessly; the fact
that the misconduct had no impact on the research record; and the fact that the misconduct was
an isolated incident. I have also considered other relevant circumstances. See 45 CFR § 689 .3(b).

Based on the foregoing, I am imposing the following action on you:

    •   You are required to complete a comprehensive responsible conduct ofresearch training
        within one year from the date that the research misconduct detetmination becomes final,
        and provide documentation of the program's content. The instruction should be in an
        interactive fommt (e.g., an instructor-led course, workshop, etc.) and should include a
        discussion of plagiarism.

    •   Fot one year from the date that the research misconduct dete1mination becomes final,
        you are required to submit certifications that any proposals or reports you submit to NSF
        do not contain plagiarized, falsified, or fabricated material.
                                                                                              Page3


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,
Virginia 22230.

Appeal Procedures for finding of Research Misconduct

Under NSF's regulations, you have 30 days after receipt of this letter to submit an appeal of this
finding, in writing, to the Director of the Foundation. 45 CFR § 689.1 O(a). Any appeal should be
addressed to the Director at the National Science Foundation, 4201 Wilson Boulevard,
Arlington, Virginia 22230. If we do not receive your appeal within the 30-day period, the
decision on the finding of research misconduct will become finaL For your information, we are
attaching a copy of the applicable regulations.

Should you have any questions about the foregoing, please con                     Assistant
General Counsel, at (703) 2 9 -

                                                     Sincerely,




                                                    Richard 0. Btickius
                                                    Acting Chief Operating Officer



Enclosures:
Investigative Report
Nonprocurement Debarment Regulations
FAR Regulations
45 CFR Part 689