Responsible Conduct of Research (RCR)

Student Involvement in Research Funded by NIH & NSF

  1. Purpose and Regulatory Background

Instruction in the standards and ethics of research is an essential part of professional development for all researchers. The federal government has significantly expanded these requirements under the CHIPS and Science Act of 2022, shifting the focus from "Research Ethics" to "Research Security and Integrity."

This policy implements the requirements of:

    • National Science Foundation (NSF): Section 7009 of the America COMPETES Act and Sections 10337 and 10634 of the CHIPS and Science Act of 2022.
    • NSF Faculty Mandate, Effective Date: July 31, 2023
    • National Institutes of Health (NIH): NOT-OD-10-019, NOT-OD-22-055, and NOT-OD-25-133 (Integrity & Disclosure).
    • NIH Other Support Training, Effective Date: October 1, 2025
  2. Applicability: Who Must be Trained?

Compliance is mandatory for the individuals listed below. Failure to complete training may result in the suspension of grant funds.

    1. NSF-Funded Personnel (Effective July 31, 2023)

ALL individuals supported by NSF to conduct research, including:

      • Principal Investigators (PIs) & Co-PIs
      • Faculty & Senior/Key Personnel
      • Postdoctoral Researchers
      • Graduate & Undergraduate Students
    2. NIH-Funded Personnel
      1. Trainees & Fellows: All trainees, fellows, participants, and scholars receiving support through any NIH training, career development award (individual or institutional), research education grant, or dissertation research grant (e.g., D43, F32, K01, K23, T32, R25).
      2. Senior/Key Personnel (New for 2025): Effective October 1, 2025, all Senior/Key Personnel on NIH awards must complete the 'Other Support & Foreign Influence' disclosure training module pursuant to NOT-OD-25-133. This is a separate requirement from the student RCR training and focuses specifically on federal reporting accuracy.
      3. Policy Requirements: The "Two-Track" System

To accommodate different regulatory requirements, the University has established two training tracks.

Track A: Faculty & Senior Personnel (NSF & NIH)
Applies to: Faculty, PIs, Co-PIs, and Senior Personnel.
Requirement: Certification must be completed within 30 days of the award start date and renewed every 4 years.
Format: Online Modules (CITI) + Attestation.

Required Curriculum:

        1. NSF RECR Core: Data Management, Authorship, Peer Review, Research Misconduct
        2. Mentorship Training (NSF Mandate): Training on mentor/mentee responsibilities.
          • Note: This module focuses on scientific rigor, career development, and psychological safety.
        3. Research Security & Export Control (CHIPS Act §10634):
          • Risks of foreign influence and theft of intellectual property.
          • Federal disclosure requirements (Current & Pending/Other Support).o Export control regulations (EAR/ITAR).

Track B: Students & Trainees (NSF & NIH)
Applies to: Undergraduates, Graduate Students, and Postdocs.
Requirement: Certification must be completed within 90 days of appointment.
Format: Hybrid (Online + Face-to-Face).

Required Curriculum:

        1. Online CITI Course: RECR for Students
        2. Face-to-Face Instruction (NIH Mandate):
          • NIH Trainees: Must complete at least 8 contact hours of face-to-face (or
            synchronous video) discussion-based instruction.
          • NSF Students: Must complete at least 1 hour of face-to-face discussion
            with their faculty mentor regarding the specific ethical challenges of their
            project.
  1. Training Topics

Per federal regulations, the curriculum for all tracks must cover the following subject
matter:

    • Mentorship and Mentor/Mentee Responsibilities
    • Research Security and Intellectual Property
    • Research Security & Disclosure of Other Support
    • Foreign Malign Talent Recruitment Programs (FMTRP)
    • Conflict of Interest (personal, professional, and financial)
    • Data Acquisition, Management, Sharing, and Ownership
    • Research Misconduct (falsification, fabrication, plagiarism)
    • Responsible Authorship and Publication
    • Peer Review
    • Collaborative Research (including with industry and foreign institutions)
    • Safe Research Environments (harassment-free research)
  1. Responsibilities
    • Principal Investigator (PI): The PI is responsible for ensuring that all personnel (including themselves) complete the required training. For Student/Trainee (Track B) personnel, the PI must facilitate the required face-to-face discussions.
    • Office of Sponsored Programs (OSP): OSP will verify training completion at the time of award setup. Grant funds will not be released until the PI and all Key Personnel have verified their certification.
    • Researchers: It is the individual responsibility of every researcher to maintain valid certification and disclose any changes in "Other Support" immediately.
  1. Reporting & Documentation

The Office of Sponsored Programs (OSP) maintains the official system of record for all RECR training.

    1. Certification of Training:
      • NSF: The Authorized Organizational Representative (AOR) must certify on each grant proposal that the institution has a plan to provide appropriate training and oversight.
      • NIH: The Principal Investigator must describe the RECR instruction plan in the grant application (e.g., K-award career development plan or T32 training plan) and report on participation in the Annual Progress Report (RPPR).
    2. Internal Documentation:
      • Individual training certificates (CITI completion reports or attendance logs for face-to-face sessions) must be retained by OSP for 3 years after the
        close of the grant.
      • The "RECR Documentation Form" (attached as Appendix A) must be signed by the PI and the trainee/researcher and submitted to OSP within the deadlines specified.
    3. Annual Reporting (NIH Specific):
      • For NIH progress reports (RPPR), the PI must upload a description of the face-to-face training activities undertaken by trainees during the reporting period.
  1. Non-Compliance

Failure to comply with this policy places the University and the individual researcher at risk of federal enforcement.

    • Consequences: If training is not completed within the designated timeframe, OSP will freeze the grant account. No expenditures (including salary or supplemental compensation) will be permitted until compliance is restored.
    • Reporting: Unresolved non-compliance may be reported to the respective federal agency (NSF, NIH) as required by the terms of the award.

Federal Regulations & Guidance

  1. CHIPS and Science Act of 2022 (Public Law 117-167)
    • Section 10337: "Responsible Conduct of Research" (Expands requirement to faculty/senior personnel).
    • Section 10634: "Research Security Training Requirement" (Mandates training on foreign influence and security risks).
  2. National Science Foundation (NSF)
    • PAPPG (NSF 23-1 & 24-1): Chapter IX.B "Responsible and Ethical Conduct of Research (RECR)."
    • America COMPETES Act of 2007: Section 7009 (Original mandate for students/postdocs).
  3. National Institutes of Health (NIH)
    • NOT-OD-10-019: "Update on the Requirement for Instruction in the Responsible Conduct of Research."o NOT-OD-22-055: "FY 2022 Updated Guidance: Requirement for Instruction in the Responsible Conduct of Research" (Clarifies face-to-face vs. virtual formats).
    • NOT-OD-25-133: "New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure" (Effective Oct 1, 2025).