The Key — Reforming Research Integrity at Penn
Penn just rewrote the rules for how it investigates research fraud. This week, the university approved a new Policy for Reviewing Alleged Research Misconduct. The policy establishes a single set of procedures for handling allegations of research misconduct — fabrication, falsification, or plagiarism — across Penn. It replaces two separate frameworks that previously governed faculty and non-faculty researchers separately.
This update creates one unified playbook for all researchers, bringing Penn into closer alignment with current federal regulations and evolving best practices.
In our discussion last week of Penn’s Faculty Senate, we highlighted the body’s advisory role and its mandate to serve as the unified voice of the faculty. One of the Senate’s core responsibilities is oversight of disciplinary policies, and both the Faculty Senate Executive Committee and Committee on Faculty and Administration participated in approving this new policy.
Penn is acting amid heightened scrutiny of research integrity across academia.
At Harvard, plagiarism allegations against former president Claudine Gay contributed to her resignation. Separately, Harvard revoked business school professor Francesca Gino’s tenure, the first-ever revocation of tenure in Harvard’s history, following the school's investigation into allegations that she manipulated data in multiple studies.
Penn is not immune to these challenges. In 2023, the Department of Health and Human Services found former Perelman School of Medicine associate professor William Armstead responsible for research misconduct. The department found he falsified records in five published studies, manipulating data in 51 figures representing his findings. Following Penn’s internal investigation, Armstead left the university and later agreed to a rare seven-year ban on receiving federal research funding.
Cases like these erode trust and undermine universities’ ability to sustain credible research. Penn’s policy update signals a renewed commitment to research excellence, strengthening oversight, procedural fairness, regulatory compliance, and protections for good-faith reporting.
Critical policy changes
Penn’s updated policy tightens intake, adds structure, and clarifies protections, representing a meaningful step in building further confidence in how the university safeguards research integrity.
One unified policy for all researchers – Penn now applies one research misconduct policy across faculty, students, postdoctoral fellows, and staff, replacing separate role-based frameworks.
Centralized intake through a Research Integrity Officer – All allegations go through a Research Integrity Officer, standardizing how cases are screened and initiated.
A new “Assessment” stage – A new preliminary assessment phase screens allegations for credibility and scope before a formal inquiry begins.
Expanded and clarified definitions of misconduct – The policy sharpens the definition of research misconduct while explicitly excluding categories that often create confusion like authorship disputes and self-plagiarism, which are handled through other channels.
Longer, more structured timelines – Clear timelines now govern inquiries and investigations, allowing for more thorough and defensible reviews.
Stronger procedural protections for respondents – Respondents are guaranteed structured opportunities to review findings, raise procedural concerns, and submit a final appeal.
Enhanced confidentiality and anti-retaliation safeguards – The policy strengthens protections for good-faith reporting and acknowledges the importance of restoring reputations, through academic leadership actions, when allegations are unsubstantiated.
Closer alignment with federal research sponsor requirements – The policy explicitly accommodates federal sponsor requirements and ensures alignment between Penn’s process and evolving federal research and grantmaker standards.
Why this matters
Trust is key to serious academic research. When allegations of misconduct are mishandled, unclear, or inconsistently enforced, confidence erodes among researchers, research sponsors, and the public alike.
A unified system lowers the odds that similar allegations produce different results depending on someone’s role. A triage stage makes it easier to filter weak claims without ignoring serious ones. Clearer protections make reporting less risky, which increases the chance that problems surface before they metastasize. Over time, this increases the likelihood that misconduct is identified and corrected and that when problems arise, they are resolved through a process that is credible, orderly, and effective.
For Penn, research integrity is an ethical and practical requirement. Grants, collaborations, clinical credibility, policy creation, institutional reputation, and therefore delivering on the pursuit of truth, all depend on it.
Ensuring institutional trust is a continual process, and this policy marks an important step toward reinforcing integrity at the core of Penn’s research enterprise. These reforms may not be flashy, but they are what prevent failures from becoming institutional crises.
The Almanac
Curated highlights from this week’s Penn news
Penn faculty groups file motion for intervention in EEOC antisemitism lawsuit
On Tuesday, the ACLU filed a motion to intervene on behalf of five Penn-affiliated employee groups in the Equal Employment Opportunity Commission (EEOC) lawsuit against the university: the American Academy of Jewish Research (AAJR), the Jewish Law Students Association of the University of Pennsylvania Carey Law School (JLSA), the American Association of University Professors (AAUP), Penn’s AAUP chapter, and the Penn Association of Senior and Emeritus Faculty (PASEF). The EEOC case alleges employment discrimination against Jewish faculty, staff, and student workers at Penn.
As we discussed a few weeks ago, the EEOC has subpoenaed Penn for lists of employees affiliated with Jewish studies, organizations, and causes on campus. Penn has refused and must formally respond to the subpoena by January 20.
The intervening groups support Penn’s position. If the court grants the motion, they would join the case as defendants and file briefs arguing the subpoena should not be enforced.
So what? So far, Penn has taken a firm stance against producing these lists. If the university ultimately chooses not to continue litigation and the motion to intervene is granted, the intervening groups could continue litigation. This motion highlights deep concerns about employees’ privacy and their belief that protecting personal information is essential to sustaining trust.
Penn unveils private graduate loan program to replace federal loans
Peer institutions and states are exploring alternatives too. Yale is planning a university-backed loan program for graduate students, and Connecticut lawmakers are considering a state-level loan program to supplement the roughly $90M in Grad PLUS loans currently used by CT students. The proposal would rely on existing state infrastructure and offer borrowing that is a “more affordable financing option” than Grad PLUS.
So what? As we discussed a few weeks ago, the end of Grad PLUS leaves Penn and its peers with three basic choices: lower program costs, expand institutional aid, or keep tuition largely unchanged and steer students toward alternative lending. Both Penn and Yale’s moves point to the third path, with universities and states stepping in as lenders. These early moves mark the start of a broader reshaping of graduate education financing.
$2 billion alleged price-fixing lawsuit against Penn heads to trial
This week, a federal judge denied Penn’s request for summary judgment in a $2 billion lawsuit alleging Penn and 16 peer institutions colluded to reduce financial aid and inflate prices. Penn, Cornell, Georgetown, MIT, and Notre Dame, the remaining schools that have not settled, will now proceed to trial.
From 1998 to 2020, Penn participated in the “568 Presidents Group,” a consortium of elite universities that coordinated financial aid principles. Penn sought summary judgment last year, arguing that it withdrew from the group in 2020 and that its actions were lawful. The court found there is enough evidence for the claims to move forward.
So what? This development comes amid broader scrutiny of elite university pricing and admissions. In August 2025, a separate lawsuit was filed, alleging Early Decision programs (like Penn’s) suppress competition and financial aid by limiting applicants’ ability to compare offers. More than a dozen schools, including Brown, Yale, and Columbia, have already settled the 568 case, paying a combined $320 million. Regardless of how this litigation unfolds, Penn continues to face a broader trust crisis, with its value increasingly questioned by both the public and federal regulators.
$50M investment fund launches for Penn life science startups
Penn is partnering with German biotech firm BioNTech and Philadelphia VC firm Osage University Partners to launch the Penn-BioNTech Innovative Therapy Seed Fund (PxB), a $50M fund for Penn life science startups. Osage will manage the fund.
Osage has invested in Penn research spinouts for over 15 years through profit-sharing agreements with the university. Under this new model, Penn will directly share in investment returns, allowing profits to be reinvested into university operations. PxB builds on Penn’s recent push toward directly investing in campus-founded startups, including the recently announced $10M StartUp Fund offering up to $250,000 per company.
PxB follows Penn’s lucrative mRNA licensing success and other healthcare partnerships and addresses a gap in early-stage life-science funding, where many VC firms wait for clinical results before investing.
So what? As NIH funding faces growing uncertainty from cuts and caps, PxB reflects Penn’s turn toward private-public partnerships to support research. Diversifying funding sources will be critical in a changing federal funding landscape and is likely to be addressed through Penn Forward’s Research Strategy and Financing recommendations.
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