College Grants & Sponsored Programs

Policy for Training in the Responsible and Ethical Conduct of Research (RECR) and Responsible Conduct of Research (RCR)

(Last updated 06/14/2023)

1. BACKGROUND
Section 7009 of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science (COMPETES) Act (42 USC 1862o–1), as amended, requires that each institution that applies for financial assistance from the National Science Foundation (NSF) for science and engineering research or education describe in its grant proposal a plan to provide appropriate training and oversight in the responsible and ethical conduct of research (RECR) to undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel supported by the proposed research project. Such training must include mentor training and mentorship. Additionally, instruction in responsible conduct of research is required for all trainees, fellows, participants, and scholars receiving support through National Institutes of Health (NIH) Institutional Research Training Grants, Individual Fellowship Awards, Career Development Awards (Institutional and Individual), Research Education Grants, Dissertation Research Grants, or other grant programs with a training component that requires instruction in responsible conduct of research (RCR) as noted in the Funding Opportunity Announcement.

Note: The requirement specified in Section 7009 of COMPETES Act (42 USC 1862o–1), as amended, to have a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to faculty and other senior personnel who will be supported by NSF to conduct research will go into effect for new proposals submitted or due on or after July 31, 2023. NSF, however, encourages the community to establish such training and oversight for faculty and other senior personnel prior to the July 31, 2023, implementation.

1.1. NSF Policy on Responsible and Ethical Conduct of Research (RECR)
The NSF “Proposal & Award Policies and Procedure Guide”[1] provides detailed information about the assurances required of all grant applicants and award recipients. Background information and details on institutional responsibilities pertaining to RECR are documented in Part II: Award, Administration and Monitoring of Grants and Cooperative Agreements, Chapter IX: Grantee Standards, Part B: Responsible and Ethical Conduct of Research (RECR)[2].

Note: Union College extends NSF’s RECR training requirement to postbaccalaureate researchers supported by an NSF-funded project.

1.2. NIH Policy on Responsible Conduct of Research (RCR)
NIH requires that all trainees, fellows, participants, and scholars receiving support through any NIH training, career development award (individual or institutional), research education grant, and dissertation research grant must receive instruction in responsible conduct of research. This policy also applies to any other NIH-funded programs supporting research training, career development, or research education that require instruction in responsible conduct of research as stated in the relevant funding opportunity announcements. The purpose of the NIH “Update on the Requirement for Instruction in the Responsible Conduct of Research”[3] is to update the agency’s policy on instruction in the responsible conduct of research, to convey some of the consensus best practices that have evolved in the research training community over the past two decades, and to provide access to additional information that may be useful to institutions and individuals in meeting their obligations under NIH policy.

2. TRAINING PLAN
This policy and related procedures are designed to assist faculty, postdoctoral, graduate, postbaccalaureate, and undergraduate researchers funded through an NSF grant or an NIH grant with a required training component in completing training in RECR/RCR.

2.1. Training Participants
Undergraduate, postbaccalaureate, graduate, and postdoctoral researchers who are contributing to an NSF- or NIH-funded research effort as part of a current/active NSF or NIH grant are required to satisfactorily complete a training course. Faculty and other senior personnel who are supported by NSF to conduct research are encouraged to complete a training course and will be required to for all funded proposals submitted or due on or after July 31, 2023.

2.2. Training Timeframe
PIs are responsible for ensuring researchers, including the PIs and Senior Personnel (effective for new proposals submitted or due on or after July 31, 2023), supported through their grant(s) complete training at the start of work on the research project and no later than thirty (30) days immediately following the initiation of NSF- or NIH-funded research.

2.3. Training Methods
Researchers are required to complete the training available through the CITI Program [4] online training modules. Researcher can register for the program by following these instructions: RECR Training - CITI Program Registration Instructions. Note: NIH training requirements may vary.

2.3.1. Instructions for Researchers – Completing the RECR/RCR Training Requirement
The faculty researcher will direct trainees to use the online tool. Trainees should register for the CITI Program by following these steps: RECR Training - CITI Program Registration Instructions.

2.3.2. Instructions for Faculty – Reporting Completion of the RECR/RCR Training Requirement
The Grants Office will email an RECR Training reminders to PIs and co-PIs in early June, early September, and early January each year. The email will include a link to the RECR/RCR Training Report Form (also available on the Grants Office website, under Policies & Forms). Upon completion of the training, the PI will:

  1. Complete the RECR/RCR Training Report Form
    1. For all NSF grants, list “other” research personnel including undergraduate, graduate, postbaccalaureate and/or postdoctoral researchers compensated through the grant.
    2. For NIH grants, list all trainees, fellows, participants, and scholars receiving support through any NIH-funded program that requires instruction in responsible conduct of research (as stated in the relevant funding opportunity announcement).
  2. Print, sign, and date the RECR/RCR Training Report Form
  3. You may attach Certificates of Completion from training programs/modules, if applicable.
  4. Return the RECR/RCR Training Report Form and any applicable attachments via campus mail to Mercedes Susi, Grants Office – 17 South Lane, 2nd Floor, or scan and email the form and attachments to grantsoffice@union.edu.

3. TRAINING ADMINISTRATION
The Director of Sponsored Programs and Special Projects and Senior Associate Director of Sponsored Programs & Faculty Fellowships will inform PIs of this training in RCR requirement during the pre-award/proposal preparation process. The PIs and co-PIs will receive an email reminder and shall complete the RECR/RCR Training Report Form as described above and return to the Senior Associate Director of Sponsored Programs & Faculty Fellowships.

[1] https://new.nsf.gov/policies/pappg/23-1

[2] https://new.nsf.gov/policies/pappg/23-1/ch-9-recipient-standards#b-responsible-and-ethical-conduct-of-research-recr-9c7

[3] https://grants.nih.gov/grants/guide/notice-files/NOT-OD-10-019.html

[4] https://about.citiprogram.org/en/homepage/