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

1. BACKGROUND
In response to the America COMPETES (Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science) Act, Section 7009, effective January 2010, the National Science Foundation requires that institutions receiving NSF grant funds in which undergraduate, graduate students, or postdocs are listed as research personnel, must provide Responsible Conduct of Research (RCR) training to those individuals participating in the research project. RCR training is also required for National Institutes of Health (NIH) grant programs with a training component that requires instruction in responsible conduct of research as noted in the Funding Opportunity Announcement.

1.1. National Science Foundation (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].

1.2. National Institutes of Health (NIH) Policy on Responsible Conduct of Research
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, 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 investigators and student and postdoctoral researchers, funded through an NSF grant or an NIH grant with a training component, in completing the requirement for training in RCR.

2.1. Training Participants
Only students 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 or modules on the RCR. See the Training Methods section below for general guidelines on training methods based on levels of participation in research activities.

2.2. Training Timeframe
Faculty PIs are responsible for ensuring their student research assistants complete the training at the start of work on the research project or no later than within one (1) academic term or during the summer research period immediately following the initiation of NSF or NIH-funded student research.

2.3. Training Methods
Faculty PIs have the option to:

1. Design customized training modules for their research assistants; or
2. Utilize the CITI Program [4] online training modules. To utilize this option, students should register for the program by following these instructions: RCR Training - CITI Program Registration Instructions.

2.3.1. Guidelines for Levels of Participation in Training
To determine the amount of training in RCR that is sufficient and appropriate for the student researchers, the PI may wish to consider students’ time commitment and level of involvement in the sponsored research activities. Those participating in research for an abbreviated amount of time may be well suited to take a basic training course, whereas summer research assistants, for example, would need a course with more in-depth exposure to issues relevant to the RCR.

2.3.2. Instructions for Students – Completing the RCR Training Requirement
The faculty researcher will provide the student with training material or direct the student to use the online tool. Students using the online CITI Program training should register by following these steps: RCR Training - CITI Program Registration Instructions.

2.3.3. Instructions for Faculty – Reporting Completion of the RCR Training Requirement
The Grants Office will email an RCR Training reminder to all PIs and co-PIs in early June, early September, and early January each year. The email will include a link to the RCR Training Activity Sheet (also available on the Grants Office website, under Policies & Forms). Upon completion of the training in a timely fashion, the faculty PI will:

1. Complete the RCR Training Report Form
   1. For all NSF grants, list “other” research personnel including undergraduate students, graduate students, and/or post-docs compensated through the grant (i.e., budget category B. Other Personnel, lines B.1., B.3., and B.4.).
   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 RCR Training Report Form
3. You may attach Certificates of Completion from training programs/modules, if applicable.
4. Return the RCR Training Activity Sheet 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 RCR Training Report Form as described above and return to the Senior Associate Director of Sponsored Programs & Faculty Fellowships.

[1] https://www.nsf.gov/pubs/policydocs/pappg22_1/index.jsp

[2] https://www.nsf.gov/pubs/policydocs/pappg22_1/pappg_9.jsp#IXB

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

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