oversight

Plagiarism (Verbatim)

Published by the National Science Foundation, Office of Inspector General on 2014-11-21.

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: Al3010008                                                                   Page 1 of 1



                OIG conducted an investigation into an allegation of plagiarism in two NSF proposals 1.
         Upon further review, we identified text copied verbatim without appropriate credit in eight
         proposals submitted to NSF. OIG concluded, based on a preponderance of the evidence, that the
         Subject knowingly committed plagiarism in those proposals, which was a significant departure
         from accepted practices. We recommended NSF take actions to protect the federal interest. The
         Deputy Director concurred and took appropriate action.

                The attached Report of Investigation describes our investigation that resulted in NSF
         making a finding of research misconduct and debarring the PI for one year. The closeout
         documents consist of this Memorandum, our report, and NSF's adjudication. This case is Closed
         with no further action taken.




NSF OIG Form 2 (11102)
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SENSITIVE                                                                              SENSITIVE




       National Science Foundation
        Office of Inspector General




                Report of Investigation
               Case Number A-13010008
                          February 28, 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)
                                           --- l   :·. -------




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                                    Executive Summary

Allegation:,    ·Plagiarism.

University Action:
                 Th~ University identified potentially copied text in two journal manuscripts
                 and two proposals submitted to NSF. It conducted an investigation that
                 concluded, based on a preponderance of the evidence, that the Subject
                 intentionally committed plagiarism, which was deemed a significant departure
                 from accepted practices. The University placed a letter of reprimand in the
                 Subject's file and will require that he undergo special scrutiny when
                 submitting any future grant applications.


OIG Investigation
and Assessment:
                •    The Act: The Subject committed plagiarism in 8 proposals that contain
                     509 unique lines of copied text, 1 figure, and 4 embedded references
                     plagiarized from 31 sources.
                 •   Intent: The Subject acted knowingly.
                 •   Standard of Proof: A preponderance of evidence supports the conclusion
                     that the Subject knowingly committed plagiarism.
                 •   Significant Departure: The Subject's plagiarism represents a significant
                     departure from accepted practices of his academic fieid. ·
                 •   Pattern: Eight proposals the Subject submitted to NSF contain plagiarism.

OIG
Recommends:·
                 •   Make a finding of research misconduct against the Subject
                 •   Send the Subject a letter of reprimand.
                 •   Debar the Subject for one year from the date of NSF's finding.
                 •   Require certifications from the Subject for a period of three years post-
                     debarment.
                 • Require assurances from the Subject for a period of three years post-
                     debarment.
                 • Require certification of attending an RCR class within one year.
                 • · Bar the Subject from serving as a reviewer during the debarment period
                     and for three years post-debarment.




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                                        University's Inquiry
                                                                              2
        The University1 received an allegation that a professor (the Subj ect ) plagiarized text in
 two proposals3 submitted for university review with the intention of submitting them to a major
 professional association4 . The University's pre-inquirycommittee5 determined the allegation
 met the definition of research misconduct6 , and was sufficiently credible to merit further
 evaluation. 7

           The Preliminary Inquiry Committee ("PIC") reviewed the two proposals and the alleged
  source documents 8. for evidence of plagiarism. The Subject, in response to the allegation,
  indicated he had mistakenly submitted an unfinished draft of the proposal due to time
· constraints 9. He stated the unfinished draft contained online information he collected for the
  proposal that he did not alter because he "did not want to lose its meaning since he was not an
  expert in the field." 10 He further explained the information in the allegedly copied sections was
  "common and well known information," 11 and he "never was maJ.dllg the claim in the proposals
                              12
  that it was his own work." However, the Subject did acknowledge that verbatim text taken
                 .                                      13
  from others should be denoted by quotation marks.

        The PIC also identified potential plagiarism within two proposals submitted to NSF by
 the Subject 14 ("Proposal I" and "Proposal2"). At the PIC's request, we reviewed the NSF
 proposals with our plagiarism software and provided the results to the PIC. Based on the results
 and other evidence, the PIC concluded an investigation was warranted.

                                      University Investigation
                                                                                  15
        Consistent with our policy, OIG referred the matter to the University • A Full
 Investigation Committee ("Committee") examined the Subject's two internal proposal
 submissions and alleged source documents, the two NSF proposals and the plagiarism reports
 generated by OIG, and conducted an interview with the Subject. It found "extensive" plagiarism




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         in both NSF proposals and one of the internal proposals. 16 They determined the second internal
         proposal "seems to contain some plagiarized material, but on a smaller scale." 17

                 During his interview with the Committee, the Subject acknowledged "he should have
         used quotation marks and it was a stupid mistake," 18 but argued that because a number of
         sections of unattributed text were background materials, including text copied verbatim from
         Wikipedia, no citation to the original source was necessary. The Committee "disagrees with [the
         Subject's] contention" 19 that he had made allowable use of background materials. They noted
         "common knowledge refers to the concept, not the verbatim use of other people's words" 20 and
         expressed skepticism that the Subject was not aware of proper citation practices. The Committee
         "feels that [the Subject] is not naive with regards to the concept of plagiarism" and observed 'it
         is clear from [the Subject's] interview that he knew the proper procedures for use of quotation,
         referencing and citation." 21       ·


                  The Committee concluded, based on a preponderance of the evidence, that the Subject
          intentionally committed extensive plagiarism in several proposals, including both of the NSF
          proposals at issue. It found the Subject acted intentionally, in part because he showed "a pattern
          of continued use of whole verbatim sentences and sections, including sentences where (he]
          interposed one or a few words within the sentence or section, showing intent to alter the sentence
        · to appear as if he had drafted the sentences or section."22 It also emphasized "that in his role as
          Associate Editor" for a respected journal, "he should be well aware of what constitutes
          plagiarism." They further concluded that "the plagiarism committed by [the Subject] was clearly
          a departure from accepted practices. " 23 .

                                       Subject's Response to University Report

                 In his response to the University's report, 24 the Subject reiterated that the copied portions
         of the proposal did not require citation because they did not ··represent a new idea to be funded
         for a research project"25 and were "background materials only and therefore cannot be viewed as
                                                                       26
         a misappropriation of the intellectual property of another." He also claimed to have been
                                                                    27
         "influenced by the changing standards on the Intemet," arguing "[i]t has become common and
         accepted practice to include source material as references at the end of articles (without including
         citations within the article directly next to the material) and doing so clearly-indicates there is no
         intent to represent that work as the author's own."28 The Subject further asserted that some of




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the copied text was "in the public domain" 29 because the source30 material was found on a
website. The Committee determined the Subject's comments did not alter their'findings or the
conclusion that he committed plagiarism.

                                     University Adjudication

        The University's adjudicato2 1 accepted the Committee's findings and recommendations.
He placed a formal letter ofreprimand32 in the Subject's personnel file and will require that he _
                                                                          33
"undergo special scrutiny when submitting any future grant applicatioris." The University is
also "continuing implementation of mandatory training of responsible conduct of research
                                                            34
training for all individuals related to research activity."

                                        OIG's Investigation
       We conclude that the University's report is both accurate and complete, and the
University follow~d reasonable procedures in conducting its investigation. 35 Because the
Subject exhibited a pattern of plagiarism in the documents reviewed by the University, we
conducted our own investigation to determine if plagiarism existed in additional NSF proposals.

        Despite the Subject's claim that "he does not believe ... that there are errors in his past
          36
work," we found additional plagiarism in a number of his previous NSF proposals. In total, the
eight NSF proposals, including the 2 analyzed during the University's investigation, contained
509lines of unique copied text The table below shows the text the Subject copied by source
into each of those proposals.




35
     45 C.F.R § 689.9(a).
36    .



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                                                                  Copied_
                     Lines of copied     Lines of unique        embedded
                          text             copied text          references        Copied figures
              37
  Proposal1                 56                 56                    0                  0
  Proposal2 38            . 55                 55                    0                  0
  Proposal·3 39             25                 25                    1                   1
  Proposal440               51                 51                    0                   0
  Proposal 5 41             162                162                   3                   0
  Proposal 642              166                135                   0                   0
  Proposal7 43              62                   0                   0                   0
             44
  Proposal 8                73                  25                   0                   0
     Total                 650                 509                   4                   1

     . A total of 650 lines of copied text were found, 509 ofthem unique, as well as four total
embedded references and one copied figure, taken from a total of 31 sources. Two of the eight
proposals each contained more than 160 lines of copied text. We also examined a number of
published papers authored by the Subject and determined those papers did not contain
plagiarism.

        To identify the accepted practices of the Subject's relevant research community, we
examined the ethical guidelines of a leading professional society45 in the Subject's field. The
subject notes in his biosketch that he is a "Life Fellow'' of this society, and he served as an
associate editor forone of its journals. 46 The society's "Ethical Standards for Authors in the
Publication of [the Society's] Journals" states:




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                                    . 47

During the Committee's interview of the Subject, he agreed with the above definition of
plagiarism.48 Although the Subject c~ntends he was unaware that verbatim copying was
unacceptable, he was able to implement proper citation practices at times, such as in his journal
articles. For example, text that he plagiarized from Source 1 into Proposal 549 was later included
in Proposal 7, where the Subject distinguished the copied material from his own work with
                 5°
quotation marks. In addition, the Subject completed a course on the responsible conduct of
research at the University in September 2011. 51

                                           OIG's Assessment

       A finding of research misconduct by NSF requires that (1) there be a significant departure
from accepted practices of the relevant research community; (2) the research misconduct be
committed intentionally, knowingly, or recklessly; and (3) the allegation be proved by a
preponderance of the evidence. 52
                                            .The Acts

        The Committee found, by a preponderance of the evidence, that the Subject "intentionally
plagiarized" material in two NSF proposals and two.proposals internal to the University. Our
review found the Subject copied 509 unique lines, 1 figure and 4 references into 8 declined NSF
proposals. OIG concludes the Subject's actions constitute plagiarism under NSF's definition.




        The Committee rejected the Subject's claim that the plagiarism resulte~ from
carelessness and found the Subject acted intentionally in plagiarizing text. They determined the
Subject showed "intent to alter the sentences to appear as if he had drafted the sentences or
section."53 The CoiD.Tcittee also noted that "it [was] clear" from the Subject's interview and




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background "that he lmew the proper procedures for use of quotations, referencing, and
citation."54 We agree that the Subject acted intentionally.

                                                 Significant Departure

                                    '
        In offering material.cqmposed by others as his own, the Subject misrepresented his own
efforts and presented reviewers with an iricorrect measure of his abilities. Based on the _
Committee's finding that the plagiarism "was clearly a departure from accepted practices,"55
bolstered by the significant amount of additional plagiarism we found, we conclude the Subject's
acts of plagiarism constituted a significant departure from accepted practices.

                                               Standard o(Proo( _

        We conclude that a preponderance of the evidence proves that the subject intentionally
plagiarized, thereby committing research misconduct. 56


                                        OIG's Recommended Disposition

       When deciding what appropriate action to take upon a fmding 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. 57

                                                  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 merit. Wrule the
plagiarized textdid not have an impact on the published research record, the quantity of
plagiarized passages was significant and found in eight of his NSF proposals. Despite the
Subject's repeated assurances that there wen; no instances of copied text in previous NSF
proposals, and recurring claims that references were included for the sources, our investigation
showed these claims to be untrue. Furthermore, we fmd it troubling that the Subject did not
plagiarize in his previously published work, but plagiarized extensively in proposals submitted to


54.
55····
56
57
     45 C.F.R. § 689.
     45 C.F.R. § 689.3(b).

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 NSF over a period spanning nearly a decade. The Subject's plagiarism is rendered even more
 serious by the fact that the he serves as an editor of a major professional society's j oumal where
 there is an expectation of enforcing and maintaining the highest commitment to academic
 standards. Thus, we conclude he was aware of proper citation practices and simply chose not to
 abide by them. We therefore conclude the amount of plagiarized material and the Subject's
 blatant disregard for proper citation is sufficiently egregious to warrant a finding of research
 misconduct

                                         Pattern and Impact

        The University found extensive evidence of a pattern of plagiarism, and we subsequently
 found a more egregious pattern.


                        Subject's Response to Draft. Investigation Report

         We provided the Subject with a copy of our draft report and attachments for comment 58
 fu the Subject's responses, he asserts his practice of non-citation is common. Using the
 ..SafeAssign" plagiarism-detection tool, 59 he said he found that his "senior colleagues ...
 practice no quotation marks or paraphrasing for common knowledge and common practice . , .
 OIG can pull up any ... currently funded PI and find at least one publication that has a high
 [Safe Assign] matching score." 60 .

        The results he provided do not support his assertion about his colleagues. The Subject
 provided us with matching percentages which are not always an accurate predictor of plagiarism.
 Documents can exhibit a high matching score because they contain text from documents
 authored by the same person as the author of the document under examination. A review of
 some of the examples the Subject provided confirm that the high scores did not reflect plagiarism
 nor do his examples in any way address his lack of proper citationpractices.

          The Subject's response to our draft report did demonstrate he still does not accept
· responsibility for not distinguishing others' work from his own. He suggests "NSF and others
  should review their plagiarism guidelines, and modify them to include the lesser requirements for
  common practice and common knowledge in engineering/science." We are troubled by the
  Subject's continuing blatant disregard of proper attribution, as well as his suggestion that NSF
  should lower its ethical standards. We therefore determined the Subject's response did not
  provide adequate reason for OIG to change its original determinations and recommendations, as
  stated above.




 58
 59
 60



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    SENSITIVE                                                                                 SENSITNE


                                                 Recommendations

    Based on the evidence, OIG recommends NSF:

                 •    Send a letter of reprimand to the Subject informing him that NSF has made a
                      finding of research misconduct61
                 •    Debar the Subject for a period of one year from the date ofNSF's fmding. 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 one year of NSF's
                      finding. 63 The instruction should be in an interactive format (e.g., an instructor-
                     led course) and specifically include plagiarism.

    For a period ofthree years after the Subject's debarment:

                 •   Bar the Subject from participating as a peer reviewer, advisor, or consultant for
                     NSF. 64                                                             -
                 •   Require that for each document (proposal, report, etc.) to which the Subject
                     contributes for submission to NSF (directly or through an institution),
                        o The Subject submit a contemporaneous certification to the AlGI that the
                             document does not contain plagiarism, falsification, or fabrication. 65
                        o The Subject submit contemporaneous assurances from the Research
                             Integrity Officer or a responsible official of his employer to the AlGI that
                             the document does not contain plagiarism, falsification, or fabrication. 66




    61
-      A letter of reprimand is a Group I action(45 CFK § 689_3(a)(l)(i)).
    62
       A Group ill action 45 CF.R. 689.3(a)(3).
    63
       This action is similar to Group I actions 45 C.P.R. 689.3(a)(l).
    64
       A Group ill action 45 CF.R. 689.3(a)(3)(ii).
    65
       This action is similar to 45 CF.R. 689.3(a)(l)(iii).
    66
       A Group I action45 C.F.R. 689.3(a)(l)(iii).

                                                            9
                                                                        ·'.

                                 NATIONAL SCIENCE FOUNDATION
                                      4201 WILSON BOULEVARD
                                     ARLINGTON, VIRGINIA 22230




    OFFICE OF THE
   DEPUTY DIRECTOR




CERTIFIED MAIL -RETURN RECEIPT REQUESTED




                                                                                                    I

       Re:     Notice ofResearclr Misconduct Determination and Proposed Debarment


Dear D r . -
As a professor in
-e'University''), you served as a Principal Investigator ("Pf') on eight proposals that were
submitted to the National Science Foundation ("NSF''), which contained 509 unique lines of
copied text, one figure, and four embedded references plagiarized from 31 sources. This
plagiarism is documented in the attached Investigative Report prepared by NSF's Office of
Inspector General ("010'').

Research Misconduct

Under NSF's regulations, ••research misconduct" is defined as "fabrication, falsification, or
plagiarism in proposing or performing 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.l(a)(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 committed intentionally, or knowingly, orrecklessly; and
       (3) The allegation be proven by a preponderance of evidence.

45 CFR § 689.2(c)
                                                                                               Page2

  The OIG Investigative Report describes in detail the significant amount of plagiarized material
  which was found in eight proposals submitted to NSF over the course of almost a decade. In
  addition, the University concluded as part of its own investigation that several proposals you
  submitted to both the University and NSF contained plagiarized material. This information
. pennits me to conclude that your actions meet the applicable definition of plagiarism, as set forth
  in NSF's regulations.

 Pursuant to NSF's regulations, the Foundation must also detennine whetherto make a finding of
 research misconduct based on a preponderance ofthe evidence. 45 CFR § 689.2(c). Based on
 infonnation in both the OIG Investigative Report and the University investigation, it is clear that
 you were aware of proper citation practices as evidenced by your
 published articles, your position as Associate Editor for
-              and your participation in an responsible conduct of research ("RCR") training
 program In 2011. Despite this knowledge, you engaged in a pattern of extensive plagiarism in
 multiple NSF proposals, After reviewing the OIG Investigative Report and the University
 investigation, NSF has determined that, based on a preponderance of the evidence, the plagiarism
 was committed knowingly and 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, II, and Ill) 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 particular requirements. 45 CFR § 689.3(a)(l). Group ll 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(!1)(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 considered
 the seriousness of the misconduct; my determination that it was committed knowingly; the fact
 that the misconduct had no impact on the research record; and the fact that there was a pattem of
 misconduct spanning nearly a decade. I have also considered other relevant circumstances, such
 as your continued assertions that your actions were not wrong but are instead common practice,
 and that NSF should lower its ethical standards. See 45 CFR § 689.3(b).

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

     •   You are required to complete a comprehensive responsible conduct of research training
         course within one year, and provide documentation of the program's content. The
         instruction should be in an interactive format (e.g., an instructor-led course, workshop,
         etc.) and should include a discussion of plagiarism.
                                                                                              Page3

    •   For a period of four years, I am requiring that you submit certifications that any
        proposals or reports you submit to NSF do not contain plagiarized, falsified, or
        fabricated material.
    •   For a period of four years, you are required to subttrit assurances by a responsible official
        of your employer that any proposals or reports you submit to NSF do not contain
        plagiarized, falsified, or fabricated material.
    •   For a period of four years, you are prohibited from participating as a peer reviewer,
        advisor, or consultant for NSF.

All certifications, assurances, and 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.

Debarment

Regulatory Basis for Debarment

Pursuant to 2 CFR § 180.800, debarment may be imposed for:

        (b)    Violation of the tenus of a public agreement or transaction so serious as to affect
               the integrity of the agency program, such as - ·

               (1)    A willful failure to perform in accordance with the terms of one or more
               public agreements or transactions;



               (3)    A willful violation of a statutory or regulatory provision or requirement
               applicable to a public agreement or transaction; or

        (d)    Any other cause of so serious or compelling a nature that it affects your present
               responsibility.

In any debarment action, the government must establish the cause for debarment by a
preponderance ofthe evidence. 2 CPR§ 180.850. In this case, the OIG Investigative Report and
the University investigation support a finding that you intentionally committed plagiarism in .
eight NSF proposals. Thus, your action supports a cause for debarment wtder 2 CFR §§
180.800(b) and (d).

Length ofDebarment

Debarment must be for a period commensurate with the seriousness of the. causes upon which an
individual's debarment is based. 2 CFR § 180.865. Having considered the seriousness ofyour
actions, as well as the relevant aggravating and mitigating factors set forth in 2 CPR § 180.860,
we are proposing your debarment for one year.
                                                                                              Page4

Appeal Procedures for fmding of Research Miseonduct and Procedures Governing
Proposed Debarment

Appeal Procedures for Finding ofResearch 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 § 689.10(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.·

Procedures Governing Proposed Debarment

The provisions of2 CFR Sections 180.800 through 180.885 govern debarment procedures and
decision-making. Under our regulations, you have 30 days after receipt of this notice to submit,
in person or in writing, or through a representative, information and argument in opposition to
this debarment. 2 CFR § 180.820. Comments submitted within the 30-day period will receive
full consideration and may lead to a tevision of the recommended disposition.lfNSF does not
receive a response to this notice within the 30-day period, this debarment will become final. Any
response should be addressed                            General Counsel, National Science
Foundation, Office of the General Counsel, 4201 Wilson Boulevard, Room 1265, Arlington,
Virginia 22230. For your information, I am attaching a copy of the Foundation's regulations on
non-procurement debarment and FAR Subpart 9.4.

Should you have any questions about the foregoing, please cm1tac:t~               Assistant
General Counsel, at (703) 292-


                                                     Sincerely,



                                                     Cora B. Marrett
                                                     Deputy Director


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




                                       NATIONAL SCIENCE FOUNDATION
                                              4201 WILSON BOULEVARD
                                             ARLINGTON, VIRGINIA 22230



      ·~~ta~.;.,. +
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      OFFICE OF THE
        DIRECTOR




CERTIFIED MAIL -RETURN RECEIPT REQUESTED




       Re:              Notice ofDebarment

Dear D r . -

On                   , the National Science Foundation ("NSF'') issued you a Notice of Proposed
Debannent and Notice of Research Misconduct Determination ("Debarment Notice'') in which
NSF proposed to debar you directly or indirectly from obtaining the benefits of federal grants for
a period of one year.

As reflected in the Debarment Notice, NSF proposed to debar you because eight proposals that
you submitted to NSF as the Principal Investigator (PI) contained 509 unique lines ofcopied
text, one figure, and four embedded references plagiarized from 31 sources.

In the Debarment Notice, NSF provided you with thirty days to respond to the proposed
debannent The period for submitting a response to NSF has elapsed, and NSF has not received
a response from you. Accordingly, you are debarred until                  .

Debarment precludes youfromreceiving federal fmancial and non-financial assistance and
benefits under non":'procurement federal programs and activities unless an agency head or
authorized designee makes a determination to grant an ex~ption in acc.ordance with 2 CFR
180.135. Non-procurement transactions include grants, cooperative agreements, scholarships,
fellowships, contracts of assistance, loans, loan guarantees, subsidies, insurance. payments for
specified use, and donation agreements. _
                                         --·----------




                                                                                        Page 2 of2




  In addition, you are prohibited from receiving federal contracts or approved subcontracts under
  the Federal Acquisition Regulations at 48 CFR subpart 9.4 for the period of this debarment. 2
  CFR 180.925. During the debarment period, you may not have supervisory responsibility,
  primary management, substantive control over, or critical influence on a grant, contract, or
· cooperative agreement with any agency of the Executive Branch of the Federal Government:

Should you have any questions about the foregoing, please c o n t a c t - Assistant
General Counsel, at (703) 292-   .

                                              Sincerely,




                                             · Richa~;d 0. Buckius
                                               Chief Operating Officer




                          l.