Case #1: Report suspected compliance violations.

Darla, a departmental assistant, was filing a stack of paperwork from two months ago when she came across several forms used internally in her department for approving student internship placements.  The standard procedure is for Richard, the faculty advisor for student internships, to sign all forms.  Darla is very familiar with Richard’s signature; she notices that one student’s form contains Richard’s name but is very clearly not his writing.  She compares the writing with another handwritten note in the student’s file, and it looks strikingly similar.  The form was from a previous term, and Darla knows that the student completed the internship and turned in all required verification from the placement site.  In fact, the student has since graduated with a degree from UAB.  Therefore, there seems to be no adverse outcome or impact from what may be a forged signature. But Darla still feels uneasy. 

What is Darla’s best next step?

  1. Inform her supervisor about the matter, and ask for help.
  2. Do not report the issue at all, since it seems to be a one-time-only occurrence, and the student is no longer attending UAB.
  3. Include a summary of the situation in the next regular department report to the dean’s office.

A. It is important to raise any concern that arises in one’s work at UAB, no matter when the issue is discovered.  Forgery is a serious matter, and depending on the circumstances, it could amount to fraud or misconduct.  To determine next steps, it is important to explore how the non-compliant behavior was able to occur and remain undetected for so long.  By bringing the issue to her supervisor and asking for help, Darla offers her department an opportunity to improve its policies, procedures, and processes.

Case #2: Learn the regulations applicable to one’s UAB activities.

Frank, a faculty member working on a small, departmentally-funded artificial intelligence project, is very excited about some preliminary results that suggest a possibility of significant cost savings in using his new approach to monitor unmanned drones.  He knows that a foreign government is very interested in developing its program, and he wonders whether he may share some of his preliminary data in a proposal to foreign officials for a contract to fund the remainder of his research.

What is Frank’s best next step?

  1. Explore the UAB Export Control website to determine whether there are federal laws and regulations governing his work.
  2. Ask his Associate Dean for Research whether there are restrictions on sharing his data.
  3. Call the Office of Sponsored Programs to discuss whether export control laws and regulations apply to the proposal.
  4. All of the above.

D.  Any “export” of controlled items or information to a foreign country or a foreign national may require a license prior to its transfer.  In this case, Frank should raise questions since he is unsure about the most appropriate way to proceed.  He should also get more information about how to proceed on the UAB Export Control website, discuss the matter with his Associate Dean for Research, and ask the Office of Sponsored Programs to review his proposal.

Case #3: Be proactive to prevent compliance violations.

Barbara is a new research assistant and is being oriented to the animal lab by Fred, a research associate who manages the lab’s daily activities.  Fred describes for Barbara the special husbandry needs of a particular population of mice that she will be working with and tells her that there are orders to “do not feed.”  Barbara does not recall these special husbandry needs appearing in the study protocols she reviewed that were approved by IACUC, and she does not see any signage for such orders posted in the lab.  She does not wish to appear naïve, but she is concerned that the lab activities and the protocols are not aligned.

What should Barbara do?

A.   Follow Fred’s instruction without question.  Given his experience, Fred has a better understanding of how the study functions.

B.   Seek clarity from Fred to ensure she understands the studies and the special husbandry needs of the animals.

C.   Report Fred to IACUC for animal research protocol violations.

B.  No matter the scope of work, UAB community members are expected provide the highest quality service. With respect to research, this means proposing, conducting, and reporting research with integrity. In this case, Barbara should seek clarity from Fred regarding the proper care for the animals in the study. By discussing it further, she can ask questions, check her understanding, and get more information about the instructions as they relate to the protocol.  It is possible that her concerns may be resolved. If, after further discussion based on all information, Barbara believes that Fred’s instructions do not allow her to conduct the study honestly, she may raise the concern to the PI, IACUC, or the research integrity officer.

Case #4: Ensure that reports of suspected violations in one's work area are resolved.

Jodi, a new post doc, is excited to obtain a highly coveted and competitive position in the lab of Dr. Harvard, a preeminent, internationally recognized cardiologist, to study novel treatment interventions and diagnostic models.  Once on board, she is asked to assist with a study involving animals.   Dr. Harvard informs Jodi that the animals are housed at another institution and that she must conduct the procedures in the evenings and on weekends.  In response to Jodi’s request for a copy of the approved animal protocol, she received an email with the protocol steps listed.   Based on those instructions, Jodi begins the procedures, but after several trips, questions begin to formulate in her mind about why dogs and pigs are being housed in the same room, why the procedures cannot be accommodated at her own institution, and why the work must be done after hours.  Jodi does not want to appear insubordinate with such questions, but she feels they are legitimate. 

What is Jodi’s best course of action?

A.   Make an appointment to discuss the matter with Dr. Harvard.

B.   Place a call to the IACUC office to ask questions about the protocol.

C.   Seek advice from the University Compliance Office.

D.   Any of the above, preferably in that order.

D.  Each UAB community member is expected to provide quality in everyday work activities, regardless of role or responsibility. With respect to animal research, this means conducting studies only in accordance with approved protocols. The UAB Enterprise Code of Conduct promotes open dialogue as a way of resolving issues. The best course of action is to discuss the matter with the PI of the study to ensure accurate understanding. If that is not a reasonable approach, other resources for asking questions are another trusted faculty member, the IACUC office, or the University Compliance Office. It is important to raise the questions, seek information, and close the loop.