Business Integrity Program

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BUSINESS INTEGRITY PROGRAM
Policy Manual
APPROVED: May 14, 1998
by BOARD OF DIRECTORS
WASHINGTON COUNTY HEALTH SYSTEM
formerly titled “Legal Compliance Program”
Revised 3/2002
23. Scientific Integrity
The Health System sometimes receives federal funds and grants to conduct scientific
research. We must comply with federal regulations relating to these funds. The rules
forbid "misconduct in science" like making deliberate false statements in proposing,
conducting, or reporting research. Honest errors or differences in data interpretation are
not considered violations.
The "misconduct regulations" are designed to prevent dishonesty in federally funded
research programs. The Health System is committed to following the regulations. We
will avoid any action that may be perceived as misconduct. Laboratory employees,
medical staff and administration (any department receiving federal finds to conduct
research) must be alert in identifying any violation of these regulations. Any suspected
violations should be reported to the Director of Business Integrity.
The federal regulations define a plan for a complete and private internal investigation of
any allegation. Evaluating these claims is complex and depends upon the specific facts
of each case. The Health System will appoint a team to investigate whether a violation
may have occurred. The team will consist of a lawyer and at least two scientists
experienced in the particular area researched. If they recommend further investigation,
we are required to notify the Office of Research Integrity of the Department of Health
and Human Services. This division monitors investigations and may conduct its own
investigation.
Violating these federal regulations could mean being excluded from federal grants and
contracts for up to three years. This exclusion can apply to the Health System and to the
scientists performing the research. There are also Federal penalties for making false
statements to the Office of Research Integrity during an investigation.
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