SUBMISSION TO NHMRC CONSULTATION ON DRAFT GUIDE FOR AUTHORSHIP 18 September 2018

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SUBMISSION TO NHMRC CONSULTATION ON DRAFT GUIDE FOR AUTHORSHIP 18 September 2018 Contact: Professor Tony Cunningham AO President Association of Australian Medical Research Institutes ABN 12 144 783 728 PO Box 2097 Royal Melbourne Hospital VIC 3050 president@aamri.org.au www.aamri.org.au

About AAMRI The Association of Australian Medical Research Institutes (AAMRI) is the peak body for medical research institutes across Australia. Our 50 member organisations work on a broad spectrum of human health issues such as preventive health, chronic disease, mental health, immunology and Indigenous health. Their research ranges from fundamental biomedical discovery through to clinical research and the translation of research findings from bench to bedside. AAMRI s members and their 19,000 staff and research students undertake over one-third of all government funded medical research. Their combined revenue exceeds $1.65 billion per annum, and they received over $622 million in competitive grant funding in 2016. With over 900 active clinical trials and over 100 new patents awarded per year, our members have a firm focus on improving health outcomes and delivering great commercial returns for the nation. Introduction AAMRI is pleased to make this submission to the National Health and Medical Research Council (NHMRC) Consultation on draft guide on Authorship, which supports the 2018 Australian Code for the Responsible Conduct on Research. This pdf is a summary of the feedback submitted through and online form on NHMRC s consultation website. 2

High-level feedback The authorship guide is a well thought through document that will be helpful to institutions and researchers in determining how to meet their authorship responsibilities. As a best practice guide it could provide further details on responsibilities of researchers in relation to publications and offer researchers and Institutions options for handling authorship disputes. We support the adoption of the authorship guide and offer the following comments to help improve the guide further. As a general comment, there are a number of important statements in the Guide in which the word should has been used. For readers this may cause uncertainty about whether the statement is desirable or required in order to meet the Code. The use of words such as must and may would give more clarity. Section 1 - Introduction The guide states that the purpose of the authorship guide is about ensuring the fairness in the treatment of others. In addition to this a statement should also be added stating that the purpose of the authorship guide also about the accountability for the integrity of research outputs and the authors responsibilities in ensuring this. Section 2.1 The definition of a substantial intellectual contribution is too loose, and further clarity is needed as to the minimum level of input required for authorship. We acknowledge that the guide is attempting to cover all disciplines, and that disciplines have a very different history and tradition when it comes to determining research authorship. However, the level of minimum input as expressed in 2.1 is too loose and could be used to justify guest authorship. For example, the guide states that a substantial intellectual contribution could involve being involved in the conception and design of the project. This could allow somebody who was just part of a conversation that led to a project being undertaken being able to take authorship credit. To provide further clarity, a table should be provided listing the four different areas outlined in section 2.1, along with examples of the level of input expected to justify authorship. This would also assist coauthors to resolve clashes between inconsistent policies of different institutions. The statement that authorship should not be attributed solely on the basis of the listed factors including provision of funding, might more appropriately be amended to provide that authorship must not be attributed solely on these bases given that to do so is a breach of the Code. The penultimate paragraph might benefit from clarifying that it is a breach of the Code by the person claiming, accepting or attributing authorship without having made a significant contribution. As currently drafted, it might imply that it could also be a breach by others involved in the publication such as co-authors or even the institution where this occurs. 3

Section 2.2 and 4.5 Given the high-level nature of the statements in 2.2, it is questionable as to how useful it is to have two sections dealing with essentially the same issue. This is particularly the case as sections 2.2 and 4.5 do not put forward identical guidance. For example, section 2.2 contains the unqualified statement: Authors should have confidence in the accuracy and integrity of the contributions of their co-authors whereas 4.5 clarifies that the obligation is to take reasonable steps to ensure the accuracy and integrity of the contributions of all other co-authors. It might be preferable to remove 2.2 and cross reference to 4.5 instead. The guide states in sections 2.2 and 4.5 that authors have a responsibility beyond their own contribution to a research output. Specifically, the guide states that: All listed authors are accountable for the whole research output. Authors are also responsible for taking reasonable steps to ensure the accuracy and integrity of the contributions of all other coauthors. This means, at a minimum, that authors should be able to identify which co-authors are responsible for specific other parts of the work It is reasonable to expect authors to undertake reasonable steps to ensure they have confidence that the contributions of others meet the expectation of the guide. However, it must be explicitly acknowledged that co-authors are not responsible for actions of unknown research misconduct undertaken by others that they could not have foreseen. For scientific papers where there are over a hundred authors there could be some practical difficulties in ensuring that all authors are aware of all other authors specific contributions to a paper, let alone be accountable for it. Section 3.1 The final sentence of the section should be changed to read WHERE APPROPRIATE, disciplinespecific guidelines should be centrally endorsed, given that the nature of research in some research institutes will mean separate discipline-specific guides are not needed. It is good to see that authorship has been broadened beyond publications to also include grant applications and tenders. However, this should also be extended to cover patent applications. Section 4.1 With respect to ensuring the appropriate and fair attribution of authorship the guide refers to R25 in the code, which covers responsibilities to ensure that only those that have contributed to the work being listed as an author. The guide should also reference R26 in the code too, which is the responsibility to acknowledge those that have contributed to the research. To reduce confusion, it might be beneficial to review 4.1 and 4.3 as they both deal with contribution other than authorship including, specifically technical writers who may be ghost authors. However, the sections deal with them slightly differently. 4

Section 4.2 As this guide should be best practice, an Authorship agreement should include a data management plan where possible and as a minimum the location of raw and analysed data of the publication (R22) as an additional dot point 5. It could also suggest the use of a secure shared electronic resource for storing, tracking and review of data. Section 4.5 In relation to responsibilities of researchers to correct the record in a timely manner (R23), this should include when errors are identified post publication and responsibility to correct the public record with erratum or retraction as required. Section 5 Guidance and options for dispute resolution processes should be included in the guide. Section 7 The definition of research output should be expanded to include patent applications. It should also be made clear here that authorship guidelines also apply to grant applications. Section 8 Appropriate links to COPE and ICMJE should be provided. 5