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Author: Alan R. Price
Title: Cases of Plagiarism Handled by the United States Office of Research Integrity 1992-2005
Publication info: Ann Arbor, MI: MPublishing, University of Michigan Library

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Source: Cases of Plagiarism Handled by the United States Office of Research Integrity 1992-2005
Alan R. Price

vol. I, 2006
Article Type: Paper
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Cases of Plagiarism Handled by the United States Office of Research Integrity 1992-2005

Alan R. Price

Associate Director for Investigative Oversight, Office of Research Integrity



Since 1992, the Federal Office of Research Integrity has been making public findings of plagiarism as scientific misconduct against individuals involved in United States Public Health Service supported research. This paper is a historical review of the 19 ORI plagiarism cases, describing the characteristics of those respondents, the PHS administrative actions taken against them, the source of the plagiarized material, and the type of person who detected the plagiarism. Almost all of the 10 plagiarists debarred by ORI/PHS from Federal funding also falsified and/or fabricated research material, thereby compounding the seriousness of their plagiarism.

The Office of Research Integrity (ORI), part of the United States Public Health Service (PHS) in the Department of Health and Human Services (HHS), has been making investigative findings of plagiarism as scientific misconduct [1] and taking administrative actions against plagiarists since 1992, [2] including publishing their names and misconduct in the Federal Register, NIH Guide to Grants and Contracts, ORI Case Summaries online, ORI Newsletter, ORI Annual Report, and the PHS Administrative Actions Bulletin Board. ORI's authority to make such findings and take such actions was published in 1989 under a Congressionally-mandated regulation, 42 Code of Federal Regulations Part 50, Subpart A. [3] This regulation supports the ethical position taken in Dr. Marcel LaFollette's book, Stealing Into Print: Fraud, Plagiarism, and Misconduct in Scientific Publishing: "A moral climate that rejects stealing [into print, i.e., plagiarism], defines it as a reprehensible act, and condemns the thief, instead of a climate that ignores plagiarism or fabrication or that excuses it according to the offender's status, will benefit everyone" (LaFollette, 1992). [4]

During its first 13 years, from 1992 to 2005, ORI has made 162 findings of scientific misconduct, including 8 for plagiarism alone and 11 for plagiarism combined with falsification and/or fabrication of research records (see Table 1).

ORI Definition of Plagiarism

It is noteworthy that ORI does not consider under "plagiarism" the reuse of material by a group of authors in redundant publications (so called "self-plagiarism"). Furthermore, ORI considers only cases of plagiarism involving persons who were not collaborators; ORI by policy does not consider authorship and credit disputes between former collaborators:

As a general working definition, ORI considers plagiarism to include both the theft or misappropriation of intellectual property and the substantial unattributed textual copying of another's work. It does not include authorship or credit disputes. . . . Many allegations of plagiarism involve disputes among former collaborators who participated jointly in the development or conduct of a research project, but who subsequently went their separate ways and made independent use of the jointly developed concepts, methods, descriptive language, or other product of the joint effort. The ownership of the intellectual property in many such situations is seldom clear, and the collaborative history among the scientists often supports a presumption of implied consent to use the products of the collaboration by any of the former collaborators. For this reason, ORI considers many such disputes to be authorship or credit disputes rather than plagiarism. Such disputes are referred to PHS agencies and extramural institutions for resolution (ORI, 1994).

This is not to say that ORI in any way condones a failure to credit properly one's collaborators; [5] instead, ORI leaves to institutions the resolution of these difficult disputes (Fields and Price, 1993).

This paper describes these 19 ORI plagiarism cases and analyses historically the characteristics of the plagiarists (respondents), the source and nature of the plagiarized material, who detected the plagiarism and made the misconduct allegation, and the nature of the Federal administrative actions imposed by ORI on those who committed only plagiarism compared to those who also falsified and/or fabricated research results.

Table 2 shows the characteristics of the 8 respondents found by ORI to have committed plagiarism alone. More than half of them were senior research faculty members (1 professor, 3 associate professors, and 1 research associate professor), and all were from major universities or medical centers. Their plagiarism was generally found by ORI not to have been a major misappropriation of significant ideas or data that would warrant debarment from all Federal funding. Therefore, ORI required most of them to certify through their institutional official that their future grant applications and reports to PHS agencies had appropriately cited all sources, and ORI prohibited them from serving on PHS advisory committees, such as study sections and advisory councils for review of grants at the National Institutes of Health (NIH) and other PHS agencies, for periods ranging from 2 to 10 years.

Debarment is the most severe administrative action that the Federal Government can take (outside of criminal or civil prosecution by the United States Department of Justice). ORI debarred only one of these eight plagiarists from receiving Federal funds for a specific period. The one plagiarist who was debarred by ORI, for 3 years, had plagiarized a whole grant application, except for his preliminary results section, from the confidential application of another scientist to a state funding agency, which he was reviewing for a colleague.

Case Descriptions for Plagiarism Alone

The following descriptions include the characteristics of the persons and material involved in these 8 solely plagiarism cases:

  • Paquette - He was a professor of chemistry at Ohio State University and a senior member of the field, accused by a former colleague of plagiarism of research design ideas, on the chemical synthesis of the anti-cancer drug taxol, from that person's NIH grant application into his own NIH grant application. On being accused, he claimed that he had given the source grant application to a postdoctoral fellow as an academic exercise, to further develop the ideas, and he had not realized that the fellow had actually plagiarized some of the words from the application; these words were incorporated by him into his grant application, unknowingly (he claimed) as to their origin. However, he refused to tell the University or ORI who the fellow was, since he said the fellow did not know that he had included the questioned materials in his application, and fearing that actions would be taken against him to damage his career (despite ORI assurances that, since the fellow had no knowledge or intent of using the material in the mentor's NIH application, ORI would not pursue the matter with him). Instead, the respondent asked ORI to sanction him (he was not debarred, but in 1993 was given 10 years of certification of his future grant applications, which he did, and prohibition from PHS advisory service).  [6]
  • Kowalski - He was an instructor in medicine at the Dana Farber Cancer Institute, after completing his residency and postdoctoral work in pathology at Harvard Medical School. He took with him an NIH grant application on the immune response to HIV/AIDS glycoprotein by his mentor, focusing on an area in which the respondent had not worked nor written for that laboratory (thus, he was not a collaborator on the source application). He copied essentially the whole application of his former mentor for use as his own NIH grant application, as alleged by a reviewer who had seen the original application at NIH. He was not debarred, but in 1993 he was given a 3-year certification and prohibition from PHS service period.  [7]
  • August - He was an associate professor of psychiatry at the University of Minnesota, who copied the text on interventions for conduct disorders from another scientist's NIH grant application that he had obtained as a peer reviewer, into his own NIH application, for which the other scientist became a reviewer. The respondent claimed that he had made an error, failing to keep track of the source of his notes, but the university and ORI found plagiarism on his part. He was required in 1994 to certify future applications and not serve as a advisor for 5 years.  [8]
  • Rosales - He was an assistant professor of cardiology in medicine at Yale University who plagiarized text on mutant protein kinase from two other group's publications for use in his own grant applications to the Veterans Administration, as alleged by a VA MERIT reviewer, as well as to NIH and to a private funding agency. He was given a 3-year certification and non-service period in 1995.  [9]
  • Landay - He was an associate professor of immunology at Rush Presbyterian St. Luke's Medical Center, who plagiarized words from several articles on flow cytometry research by others, as alleged by an original author, into two publications and a report supported by an NIH grant. In 1995 he received 2 years of certification and non-service, and he submitted corrections of 2 papers.  [10]
  • Farooqui - He was a research associate professor of dermatology at the University of Cincinnati, who plagiarized material on hormone expression in human skin from the significance section of a National Science Foundation (NSF) grant application, as alleged by a reviewer for NSF, which the respondent had obtained from another confidential reviewer and used in his NIH grant application. After ORI imposed on him in 1996 a 3-year certification and non-service period, NSF OIG expanded the case, finding more of the same plagiarism in NSF applications, so NSF debarred him for an additional period.  [11]
  • Imam - He was an associate professor of pathology at the University of Southern California who copied almost all of a grant application on human DNA telomerase enzyme to a state agency, which had been given to him in confidence by a peer reviewer. The respondent used it in his own NIH grant application, as alleged by a reviewer, who was the original applicant. In 1997, he was debarred for 3 years as well as prohibited from PHS advisory service.  [12]
  • Padgett - He was an assistant professor of oral biology from Ohio State University who plagiarized into his own NIH grant application preliminary research data on hormone enhancement of the immune response from another person's company, as alleged by a consultant to that company who had done the work and happened to become a reviewer for NIH. He was subjected by ORI in 2001 to 3 years of certification and non-service.  [13]

Table 3 indicates, for these 8 sole plagiarists, the source of the material that they plagiarized, the kind of document in which the plagiarized text appeared, and the type of person who identified the plagiarism and made the allegation to an institution, PHS agency, or ORI. All but 1 of these 8 ORI cases of solely plagiarism involved the copying of words and/or ideas in NIH grant applications, detected by a reviewer, who was in most cases the original applicant whose own grant application to NIH (or to the NSF), or the original author whose own publication, had been plagiarized; they just happened to become a reviewer for NIH or NSF of the questioned application and then reported the plagiarism to agency officials.

Case Descriptions for Plagiarism in Combination With Falsification and/or Fabrication

Table 4 describes the characteristics of the 11 respondents found by ORI to have committed plagiarism in combination with falsification and/or fabrication. Again, almost half of the respondents were senior research faculty members (1 professor, 1 associate professor, and 3 research scientists). Furthermore, 9 of the 11 respondents were from major medical centers or universities. Their relatively minor occurrences of plagiarism were associated with major falsifications or fabrications of significant data or other documents. Therefore, ORI debarred all but two of them from Federal funding, typically for 3 years or more, as well as prohibiting them from PHS advisory committee service for 3-5 years (one had to undergo certification requirements and non-service for 10 years in addition to 3 years of debarment).

The following describes the characteristics of these persons and the plagiarized material:

  • Freisheim - He was a professor of biochemistry and department chairman at the Medical College of Ohio, who plagiarized some research method designs on membrane-transport of the anti-cancer drug methotrexate, from the application of an assistant professor at another institution, for which he had been a confidential reviewer, into his own NIH grant application. When the original person, as an NIH reviewer, saw the questioned application, he raised concerns with the NIH review staff. On being informed of the allegation (without sequestration of evidence), the respondent fabricated a hand-written document that he claimed to have circulated with his ideas to the research community a year before the source application was submitted. However, the complainant then provided an application with similar words and ideas that he had submitted to NIH a year earlier than the respondent's purported document. Furthermore, the investigation committee found falsifications in the fabricated document, making clear that it could not have been written when the respondent had claimed. The institution forced him to resign. In 1993 ORI debarred him for 3 years, as well as required certification of future applications and prohibited his PHS service for 10 years.  [14]
  • Abdulahi - He was a research scientist in biology at Clark Atlanta University, who copied the research design and preliminary research from a publication on cadmium exposure, and he falsified it as data on mercury exposure for his own NIH grant application, as alleged by a reviewer. He was debarred in 1996 for 3 years, as well as prohibited from advisory committee service.  [15]
  • Qian - He was a research scientist at New Dimensions Research Instrument, Inc. the only biologist at a small business, who plagiarized 7 images from Internet sources without attribution for his NIH small business innovation research grant, including 2 images that he claimed were the output of his new imaging technology. A confidential NIH reviewer recognized one as the familiar image of calcium concentration over a brain neuron on the cover of Science magazine years earlier; so he brought forward the initial allegation, which was expanded by ORI in its investigation. ORI debarred the respondent and prohibited his service in 2000 for 3 years.  [16]
  • Jacoby - He was an instructor in neurology at the Massachusetts General Hospital and Harvard Medical School, who plagiarized the image of a Southern blot on adeno-associated virus expression from a published paper and falsified the experiments, for use in slide for a national society meeting on his herpes simplex virus amplicon. The author of the original paper was in the audience, recognized the image, and complained to the society president. The respondent had used the same falsified image for two other presentations and two grant applications. He later falsified an image to try to mislead his mentor and the investigation committee. He also forged the signature of an institutional official on his NIH fellowship grant renewal. He did not make any admission until confronted by ORI with the latter evidence, when he agreed in 2001 to be debarred for 5 years and not to perform PHS advisory service. [17]
  • Pandurangi - He was a research assistant professor in chemistry at the University of Missouri who plagiarized images on radio-iodinated receptors in rat kidneys from publications by other scientists and falsified them in supplementary material for his own NIH grant application, as alleged by an NIH reviewer who recognized the images. He also falsified other data. He denied any wrong-doing until ORI confronted him with its evidence; then he agreed in 2001 to a debarment for 1 year, plus supervision and certification for 3 years, and non-service for 4 years.  [18]
  • Xiong - He was an assistant professor of human genetics in public health from the University of Texas Health Science Center in Houston, who plagiarized material on genomic screening using linkage methods from another scientist's NIH grant application, which he had obtained as a peer reviewer, as alleged by a reviewer who was a co-investigator on the original application. The respondent also committed falsification and fabrication of data and statistical power in using it for his own NIH grant application. In 2001 ORI required that he not serve as principal investigator on any PHS grant for 1 year, and that he certify future PHS applications and not serve as an advisor for 3 years.  [19]
  • Yao - He was an associate professor of anesthesiology at the University of North Carolina who took [20] images on cytomegalovirus-infected chick cells obtained from the laboratory of a scientist at another institution, who became the reviewer for NIH, and falsified them to represent adenovirus-infected rat cells in his own NIH grant application. He also falsified other data for a publication and other applications. ORI debarred him in 2002 and prohibited his service for 5 years.  [21]
  • Karunakaran - He was a research scientist in medicine at Boston Medical Center who plagiarized a DNA sequence from an Internet data base on one strain of the oral cavity bacterium P. gingivalis and falsely reported it as research progress to his mentor on another strain. She found that it did not match an earlier sequence sheet that he had given her, but did match a GenBank sequence. He also falsified and fabricated other data. ORI debarred him in 2003 for 3 years and prohibited his service.  [22]
  • Koltover - He was a postdoctoral fellow in chemical engineering at the California Institute of Technology who plagiarized a scanning transmission micrograph from another student's experiment in their laboratory and misrepresented it to his mentor as results from an atomic force micrograph of a different molecule, as alleged by coworkers in that laboratory. The mentor used the falsified image in an NSF grant application, and the respondent used it himself as an assistant professor at a new university for a private agency grant application. In 2003 ORI required he certify his future PHS applications, be subject to close supervision, and not serve on advisory panels for 3 years.  [23]
  • Ramalingam - He was a postdoctoral fellow in biology at the California Institute of Technology who plagiarized an image on immuno-fluorescence recovery in bleached membranes from another person's publication and falsified it as a different experiment in his own NIH grant application, as alleged by an NIH reviewer who was the original author. He also fabricated other data for a manuscript (2 other papers of his were retracted). In 2004 ORI debarred him and prohibited his service for 3 years.  [24]
  • Sultan - He was an assistant professor of immunology and infectious diseases at the Harvard School of Public Health who plagiarized text and three figures, showing immunofluorescence, phosphorimage and northern blot analysis from 4 publications by other scientists, as alleged by a confidential reviewer. He falsified them as representing a different malaria-causing organism for his own NIH grant application. He also fabricated an email about the involvement of a postdoctoral collaborator in an attempt to cover up his misconduct, which he admitted after being caught in the lie. ORI debarred him and prohibited him from advisory service for 3 years in 2004.  [25]

Table 5 shows for these 11 plagiarists who also falsified or fabricated research, the source of the material plagiarized, the document type containing the plagiarized text or figure, and the sort of person who identified the plagiarism and made the allegation. All but 2 of them involved plagiarism of words and/or ideas in NIH (or NSF) grant applications, generally detected by the original author of the source publications (3 cases) or the NIH grant applicants (2 cases); in 2 others, Internet sources (images or data from databases) were recognized by a reviewer or by the mentor/P.I.; and in the other 4, a confidential reviewer whose identity is unknown to ORI made the allegation.


These data show that ORI has taken significant actions against 19 plagiarists (interestingly, all of whom were male scientists [26]) in PHS-related research, who have misappropriated words or ideas from the grant applications or publications of other scientists without crediting the source. ORI took the most severe actions against plagiarists who also falsified or fabricated data or documents, generally debarring them from Federal funding for 3 to 5 years. [27]

However, no matter how severe the administrative actions imposed, ORI publishes the name of the respondent, institution, and description of the detailed findings of scientific misconduct in:

all of which can be searched on the Internet. [28] Indeed, a Google search on "First-Name Last-Name" and NIH Guide (or ORI) generally pulls up the NIH Guide and/or ORI Website listing for the respondent at the top of the list. Thus, it is possible for other scientists and institutional officials to check easily for any ORI findings and currently active administrative actions against a specific person before making a decision on hiring or working with that person.


Fields, K.L., and Price, A.R. (1993), Problems in research integrity arising from misconceptions about the ownership of research. Academic Medicine, 68, 560-564.

LaFollette, M.C. (1992). Stealing Into Print: Fraud, Plagiarism, and Misconduct in Scientific Publishing. Berkeley, California: University of California Press.

ORI (1994). ORI's working definition of plagiarism. ORI Newsletter, Vol. 3, No. 1, p. 3, December 1994 (see also ORI Web site: <>).


1. See also an earlier paper by this author, "Federal Actions Against Plagiarism in Research," Journal of Information Ethics 5, 34-51 (Spring 1996), and a paper by Debra Parish, "Scientific misconduct and the plagiarism cases," Journal of College and University Law 21, 517-554 (Winter 1995).

2. ORI's predecessor office, the Office of Scientific Integrity (OSI), made similar findings of scientific misconduct under the same PHS regulation from June 1989 to May 1992: 10 for plagiarism, 5 for falsification, 9 for falsification and fabrication, and 1 for other misconduct). The author's 1996 J.I.E. paper on these OSI plagiarism findings compared them with plagiarism findings and actions by the United States' National Science Foundation (NSF).

3. The 1989 PHS Regulation on scientific misconduct, applicable to misconduct before June 16, 2005, is still available online at <>, with the new PHS regulation, now in effect, which defines research misconduct as "fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. . . . (c) Plagiarism is the appropriation of another person's ideas, processes, results, or words without giving appropriate credit." For the first time, the PHS regulation now includes plagiarism in "reviewing research," i.e., in peer review of PHS grant applications or PHS-supported manuscripts (even if the respondent/plagiarist did not have relevant applications to or funds from PHS agencies for the research).

4. See also other recent books, as on authorship edited by Mario Biagioli and Peter Galison (2002), Scientific Authorship: Credit and Intellectual Property in Science, Routlege, Inc., New York, New York; and on misconduct, including plagiarism in research, by Horace Freeland Judson (2004), The Great Betrayal: Fraud in Science, Harcourt Inc., Orlando, Florida.

5. Institutions and ORI have to evaluate how significant is the apparent copying of words in a plagiarism allegation. Is it commonly known background or review information, or boilerplate material that is commonly used in such grant applications? Or instead is it a substantive misappropriation of text intended to demonstrate scholarship or creativity by the plagiarist?

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20. The ORI notice in the Federal Register on this case used the word "took" instead of "plagiarized," but the other scientist was not a collaborator with the respondent, who indeed took the questioned material, through a colleague, from that laboratory, so it represented "plagiarism."

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26. Among all of the 162 respondents found by ORI since 1992 to have committed scientific misconduct, there were 23 women, 6 of whom were female junior scientists and 17 of whom were female members of the staff conducting clinical or basic research. There were no women scientists among the 19 respondents who committed plagiarism in these ORI cases.

27. ORI casefiles contain very little as to the possible reasons that these persons committed plagiarism; the institutional reports seldom mention any such statements by the respondents, and their early claims in defense (about making mistakes, forgetting sources, using temporary place-holders, computer problems, etc.) are seldom credible. Thus, the author choses not to consider reasons for plagiarism or possible means of prevention in this paper.

28. Furthermore, if a publication that was formally corrected or retracted in the literature is cited in the ORI finding, the National Library of Medicine's PubMed site for the MEDLINE database, establishes a link from the original article to the correction/retraction and/or to the NIH Guide listing of the ORI finding. In that way, researchers who are searching PubMed for relevant articles will be warned of the problem with the paper as involving scientific misconduct.

Table 1. ORI findings in cases, by misconduct groups (June 1992 through November 2005)
ORI Findings Total number of cases
Plagiarism alone 8
Plagiarism and Falsification 6
Plagiarism, Falsification, and Fabrication 5
Plagiarism and Fabrication 0
Falsification alone 59
Fabrication alone 30
Falsification and Fabrication 53
Other 1
Total number of ORI cases with findings 162
Table 2. ORI findings for plagiarism alone - 1992-2005
Respondent's Title and Institution Year/ORI ORI Administrative Actions Imposed
Debarment Certification Non-Service
Professor Ohio St. Univ. 1993 10 Years 10 Years
Assoc. Prof. Univ. Minn. 1994 5 5
Assoc. Prof. R.P.StL.M.C. 1995 2 2
Assoc. Prof Univ. So. Cal. 1997 3 years 3
Assoc. Prof. Yale Univ. 1995 3 3
Assoc. Prof. Ohio St. Univ. 2001 3 3
Instructor D.F.C.I/H.M.S. 1993 3 3
Res. Asc. Prof. Univ. Cincinn. 1996 3 3
Table 3. Nature of documents in ORI findings for plagiarism alone -1992-2005
Year / Institution Source Document Plagiarism in Document Discoverer of Plagiarism
1993     O.S.U. NIH application NIH application Reviewer/Original Applicant
1993     D.F.C.I NIH application NIH application Reviewer
1994     U.Minn. NIH application NIH application Reviewer/Original Applicant
1995     R.P.StL. Publications 2 Publications Original author
1995     Yale U. Publications NIH & VA applics. VA Reviewer
1996     U.Cinc. NSF application NIH application NSF Reviewer
1997     U.S.C. State application NIH application Reviewer/Original Applicant
2001     O.S.U. Other company NIH application Reviewer/Original Author
NOTE: The cases correspond to the same year in ORI and institution as in Table 2.
Table 4. ORI findings for plagiarism with Falsification and/or Fabrication - 1992-2005
Respondent's Title and Institution Year, PL+ ORI Administrative Actions Imposed
Debarment Certification Non-Service
Professor Med. Coll. Ohio 1993 FL/FB 3 years 10 years 10 years
Assoc. Prof. Univ. No. Carol. 2002 FL 5 5
Asst. Prof. Univ. Texas HSC 2001 Fl/FL 3 3
Asst. Prof. Harv. Sch. Pub. Hlth. 2004 FL/HB 3 3
Instructor Mass. Gn. Hosp./HMS 2001 FL 5 5
Res. Sci. Clark Atlanta Univ. 1996 FL 3 3
Res. Sci. N.D.R.I 2000 fl 3 3
Res. Sci Boston Med. Ctr. 2003 FL/FB 3 3
Res. Asst. Prof. Univ. Missouri 2001 FL 1 +3 4
Postdoc Cal. Inst. Tech. 2003 FL 3+ Superv. 3
Postdoc Cal. Inst. Tech. 2004 FL/FB 3 3
NOTE: FL = Falsification; FB = Fabrication
Table 5 - Nature of documents in ORI findings for plagiarism with Falsification or Fabrication - 1992-2005
Year / Institution Source Department Plagiarism in Doc. Discoverer of Plagiarism
1993     M.C.Oh. NIH application NIH application Reviewer/Original Applicant
1996     Cl.At.U. Publication NIH application Reviewer
2000     N.D.R.I. Internet images NIH application Reviewer
2001     MGH/HMS Publication NIH applications Original author
2001     U.Mo. Publications NIH application Reviewer
2001     U.T.H.S.C. NIH application NIH application Reviewer/Original Applicant
2002     U.No.Car. Other colleague NIH applications Reviewer/Original Author
2003     Bos.M.C. Internet database NIH application Mentor/P.I.
2003     C.I.T. P.I.'s laboratory NSF application Coworker in laboratory
2004     C.I.T. Publication NIH application Reviewer
2004     H.S.P.H. Publication NIH application Reviewer
NOTE: The cases correspond to the same year in ORI and institution as in Table 4.

Alan R. Price, Ph.D., is the Associate Director for Investigative Oversight of the Office of Research Integrity (ORI) in the Public Health Service of the Department of Health and Human Services in Washington, D.C., USA. His doctoral and postdoctoral work was in biochemistry. He was a faculty member at University of Michigan Medical School from 1970 to 1987, also serving as Assistant Dean for Research and Assistant/Associate Vice President. In 1987, he moved to the National Institutes of Health in Maryland, and then into its Office for Protection from Research Risks (OPRR). In 1990, he joined the new NIH Office of Scientific Integrity, which in 1992 became the PHS ORI. He is responsible for supervising 15 scientific and professional staff who oversee investigations of research misconduct related to PHS grants.