Written evidence submitted by the
Higher Education Funding Council for England (RIN0010)

Executive Summary

1.           There is evidence that the Concordat to Support Research Integrity is having a positive impact among UK higher education institutions (HEIs) by encouraging them to strengthen their policies to promote integrity and by allowing funders, such as the Higher Education Funding Council for England (HEFCE), to address research integrity through the link between concordat compliance and research funding.

2.           The Concordat exists within a landscape of multiple, complementary mechanisms that promote and ensure research integrity within the UK. Together, these mechanisms are an appropriate and proportionate approach to ensuring research integrity in the UK and are welcomed by the sector. They allow the maintenance of the individuality and autonomy of research institutions while fostering a positive culture of research integrity.

3.           The concordat approach can and should, however, be strengthened to enhance research integrity within the UK. Together with other signatories of the Concordat, we are seeking to take forward recommendations in this area, including: articulating expectations for compliance more clearly to HEIs and establishing the UK Research Integrity Forum. Careful consideration is also being given to the role UK Research and Innovation (UKRI) will take in assuring research integrity in the near future.

Role of HEFCE and Research Integrity

4.           The role of HEFCE is to allocate funding provided by the government to universities and colleges in England for teaching and research. HEFCE funding for research is allocated to enable HEIs collectively to maintain a research base of world leading quality across the full range of disciplines.

5.           Working with other research funders and Universities UK (UUK), we established and signed the Concordat to Support Research Integrity in 2012.[1] The Concordat sets out requirements for researchers, HEIs and other research performing organisations, and funders in the area of research integrity. The Concordat sits alongside legislative and regulatory instruments that apply to some areas of research, such as the Human Rights Act 1998, the Animals (Scientific Procedures) Act 1986, the Human Tissue Act 2004 and the Data Protection Act 1998.

6.           HEFCE requires compliance with the Concordat as a condition of grant. HEIs in receipt of research funding must provide HEFCE with assurance of their compliance with the Concordat through their annual assurance returns. To comply with the Concordat, we expect institutions that are eligible to receive our research funding to have:
1. Procedures in place to ensure that research is conducted in accordance with standards of best practice
2. Systems to promote research integrity
3. And transparent, robust and fair processes to investigate alleged research misconduct.

7.           Non-compliance with the Concordat is identified through our annual assurance returns, part of HEFCE’s normal assurance process. In cases of non-compliance, HEFCE enters into dialogue with the relevant HEI to facilitate resolution through engagement and collaborative working.

8.           HEFCE documented that 25 per cent of institutions in receipt of HEFCE research funding reported that they were ‘working towards’ compliance with the Concordat when the requirement was introduced in 2013/14. In 2014/15 4.8 per cent of institutions were continuing to work towards compliance and the remainder reported being compliant. In 2015/16 only 1.6 per cent of HEIs reported that they were still working towards compliance with the Concordat. The progress made across the sector in reaching compliance over this period highlights the benefit of our approach. The assurance process also allows HEFCE to enter into dialogue with HEIs over compliance. Institutions consider this type of engagement important to sustain and improve the Concordat and research integrity.[2]

9.           Wider evidence of compliance with the Concordat is provided in the 2016 progress report on the Concordat conducted by UUK on behalf of its eight signatories. The review reports that Research Councils UK (RCUK) have assessed 47 research organisations through its assurance process since 2012, with all being found to be compliant with the Concordat.[3] Annual narrative statements produced by institutions have also allowed monitoring of misconduct investigations.[4]

10.       The review also confirmed the value of linking compliance with research funding, noting that this ‘has been important in ensuring that implementation of the concordat has been taken seriously’ by HEIs.[5] There has been good dissemination of the Concordat since its publication and awareness among those responsible for its implementation within institutions is strong, which has raised the profile of support for and mechanisms to ensure research integrity more generally.[6] All institutions surveyed by UUK had evaluated the requirements of the Concordat against their existing internal practices, with a wide range of examples provided where the Concordat had stimulated policy and practice.[7] It is our view, therefore, that the Concordat has been successful in raising the profile of research integrity, encouraging compliance among HEIs and allowing monitoring of this.

11.       HEFCE’s 2013 consultation on the Concordat showed that 90 per cent of HEIs considered its requirements to be reasonable and proportionate. This aligns with our aim to reduce the reporting burden on HEIs where reasonably possible but maintain a dialogue with HEIs when cases of misconduct arise. The current system provides assurance and mechanisms for oversight.

12.       However, the evidence gathered to date[8] suggests that more can be done to build on the momentum generated by the Concordat’s development and to improve the transparency of information around managing research integrity, as detailed below.

13.       New and improving processes and technologies are currently already enhancing research integrity. Publishers are developing new tools that promote research integrity such as additional peer reviewing of preliminary-stage articles in some disciplines, technologies that identify wrongdoings such as plagiarism, and technologies to track retractions and corrections in publications, while peer review itself can identify suspicious research practices or misconduct.[9] Increasing numbers of institutions also have specific staff members with responsibility for research integrity.[10] Existing bodies such as the UK Research Integrity Office (UKRIO) and the Committee on Publication Ethics (COPE) provide support and advice on ethics and integrity for researchers, reviewers and publishers.

14.       There is evidence that associates open access to research data with higher research standards[11], and encouraging a culture of research integrity is one of the reasons that HEFCE is seeking to promote and incentivise open data. The 2016 Concordat on Open Research Data set out ten principles for making data openly available and noted that one of the key benefits and objectives of this was to allow better scrutiny of research.[12] The Open Data Taskforce, of which HEFCE is a co-funder, is working to produce a roadmap for open data in the UK in order to support transparency and provide assurance of high standards within research. We are currently consulting on awarding additional credit to institutions that can demonstrate activity above and beyond open access policy requirements for the next Research Excellence Framework (REF) in 2021, and on ways to incentivise the sharing of research data more effectively through the environment section of the REF.

15.       The current landscape therefore already consists of multiple, complementary methods and bodies that ensure and promote research integrity. Evidence shows that, particularly since the implementation of the Concordat, there are significant activities happening to support research integrity within HEIs.[13] This approach recognizes both the autonomy and individuality of HEIs and other research institutions. As the Concordat noted, a ‘one size fits all’ regulatory system is unlikely to be suitable[14] because institutions that employ researchers (some of which are not HEIs) have a diverse range of circumstances and mechanisms governing their research and must retain the freedom to implement policies and procedures surrounding research integrity that are appropriate to the institution’s context. The Concordat provides this flexible framework and ensures that the responsibility for research integrity remains with individual institutions, which encourages them to take active steps to ensure good practice. As UUK’s evaluation of the Concordat demonstrated, HEIs and other research institutions value highly the flexibility of the current approach and the autonomy it affords.[15]

16.       The Concordat promotes a positive culture of research integrity among both researchers and HEIs. A system of direct regulation would risk replacing this culture with one of policing bad practice.[16] As UUK has reported, institutions have already voiced concerns over this.[17] It is our view that a culture of transparency, dialogue and active integrity is preferable to one that relies on external oversight to investigate alleged misconduct after the fact. It encourages activity within institutions to create a research environment that embraces, promotes and complies with research integrity.

17.       Research that falls short of integrity standards exists along a spectrum from work which is deliberately and actively misleading or falsified, through more borderline cases to genuine, honest mistakes. As detailed in the Parliamentary Office of Science and Technology’s January 2017 POSTNote, the majority of cases are not deliberate attempts to mislead or falsify[18] and it is our view that such cases are best addressed by the current collaborative approach and assurance frameworks. This approach fosters a positive climate of research integrity, provides mechanisms for research employers to ensure integrity and guarantees that HEFCE is notified of and can act upon any issues through dialogue with HEIs.

Recommendations for enhancing research integrity

18.       As noted above, it is our view that the current approach to research integrity is satisfactory, and that this can be further strengthened in accordance with the recommendations of the progress report on the Concordat.[19] 

19.       In particular, there have been concerns over the clarity of funders’ expectations for compliance with the Concordat. HEFCE agrees that these expectations of HEIs and other research employers should be made clearer, both to promote and demonstrate compliance as well as to increase public trust in the integrity of UK research institutions. We are currently working with our co-signatories to the Concordat on a collective approach to communicating these and support the recommendation in the progress report that the focus of these expectations should be on greater transparency and accountability.[20]

20.       As a minimum, HEIs and other research employers could be obligated to have a discoverable webpage and a dedicated contact person for research integrity. They could also be mandated to publish annual narrative statements that detail the number of misconduct allegations and investigations at their institution. Currently 35 institutions produce these statements publicly.[21] If all institutions in receipt of research funding published annual narrative statements, this would enable funders to monitor research integrity processes where necessary. By being public, annual statements would act as a further deterrent to misconduct and bolster public confidence in research integrity and the processes used to ensure it. Such statements would also provide more robust information on the extent of the research integrity problem in the UK, for which there is currently little evidence. These statements themselves would not be proof of compliance with the Concordat, but would form part of the compliance framework (which would ultimately still require assurance in annual returns to HEFCE and would continue to be a condition of grant). We intend to consider carefully the way dialogue is opened up between research institutions and those with research integrity assurance roles.

21.       We are also working with our co-signatories on the establishment of a UK Research Integrity Forum. The terms of reference for this forum are currently in development, but it is our initial view that this forum would provide an effective mechanism for consistently overseeing the promotion of a positive culture of research integrity in the UK, as well as having a key role in reviewing continued progress on the Concordat. The forum could also facilitate discussions and actions on sharing examples of research integrity best practice to incentivise further and advise institutions in their own activities as well as to raise the profile of research integrity within the UK.

Research Excellence Framework (REF)

22.       The REF is a peer review-based assessment of the quality of research outputs, impact and the research environment. The REF’s emphasis on quality incentivises research integrity. The January 2017 POSTNote voiced concern that the current ‘publish or perish’ research climate undermines research integrity by incentivising poor research practices in the interest of producing large volumes of publications for prestigious journals that are perceived to have high impact.[22] However, the POSTNote also noted that the REF is not the sole driver of this and, indeed, by previously asking for only four outputs to be submitted per researcher for a seven year assessment period in REF 2014 the intention was to send a clear signal that the exercise valued quality over volume of publication. The REF also incentivises and rewards high quality rather than high volume research through its link to the research funding (driven only by high-quality outputs) that HEIs receive, further promoting research integrity.

23.       Following the independent review of the REF led by Lord Stern, the four UK higher education funding bodies are currently consulting on the framework for REF 2021. This includes a proposal to decouple staff from outputs in the assessment, with a requirement for an average of two outputs per full-time equivalent researcher but with flexibility to submit more or less than the average for each staff member. These proposed changes are intended to provide more flexibility to institutions in building submissions, and consequently give more space for focusing on longer-term research, while reinforcing the point that quality is preferred over volume in assessment. It is our view that this would further reduce perceived pressures on publishing.

24.       We are also exploring ways in which the REF can further promote research integrity. Our engagement activity on the consultation proposals has included some reflection around the potential for research integrity to be captured through the research environment element of the exercise, with some views that the proposed institutional-level assessment of the environment may offer an appropriate way to assess institutions’ activity in relation to the range of concordats relevant to research. We will seek to explore the potential options for this in detail following the consultation period.

UK Research and Innovation

25.       Subject to parliamentary approval of the HE and Research Bill, the role of UKRI – and within it, Research England – in relation to research integrity will need careful consideration in the near future. It will be important to ensure that UKRI maintains and improves upon current assurance frameworks around research integrity. It is likely that UKRI will provide opportunities for closer collaboration and dialogue between Research England and the Research Councils on research integrity, with enhanced capability across funders to gather and share information effectively. It will also provide further opportunities to review and strengthen the links between research integrity compliance and research funding.

Recommendations

26.       HEFCE invites the committee to consider the following recommendations to improve research integrity in the UK:
1. To maintain the current system of ensuring research integrity in the UK through the Concordat to Support Research Integrity and other, complementary organisations and systems rather than establishing a regulatory body.
2. To strengthen the Concordat through clarifying its expectations for HEIs and other research organisations.
3. To establish a UK Research Integrity Forum and use this to review progress and explore and implement additional strategies for ensuring research integrity, such as through collecting and disseminating examples of best practice.
4. To consider the role of UKRI in promoting and assuring research integrity as the organisation continues to take shape.

March 2017