Responsible Conduct of Research (RCR)

Student Involvement in Research Funded by NIH & NSF


Instruction in the standards and ethics of research is widely considered to be an essential part of any student training to engage in research.

National Institutes of Health (NIH): Effective 11/24/2009, the NIH updated its policy on instruction in the responsible conduct of research. The NIH requires that 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, or other NIH-funded program must receive instruction in responsible conduct of research (RCR). Faculty research advisors are highly encouraged to contribute both to formal and informal instruction in RCR.

National Science Foundation (NSF): Effective 1/4/2010, the NSF mandates that all undergraduate and graduate students and postdoctoral researchers supported by NSF to conduct research must receive appropriate training and oversight in the ethical and responsible conduct of research (RCR). In January 2019, NSF added that it strongly encourages the training of faculty in RCR.


At the time of grant proposal submission to the National Institutes of Health (NIH), the National Science Foundation (NSF), or other sponsors who adhere to either NIH or NSF guidelines, St. John Fisher University must have a plan in place to provide “appropriate training and oversight in the responsible and ethical conduct of research” to all scholars receiving support through these agencies. RCR training must be completed at least once during each career stage (e.g., undergraduate, graduate, post-doctoral, etc.) (NIH) or every four years (NSF). Principal Investigators (PIs)/Project Directors (PDs) are responsible for ensuring appropriate training and oversight in the responsible and ethical conduct of research to undergraduates and graduate students who receive direct funding from the NIH or NSF and/or are working on NIH- or NSF-funded research.

Reason for Policy

This policy covers the training requirements for all grant proposals submitted by St. John Fisher University that are subject to compliance with Responsible Conduct of Research (RCR), including those sponsored by NIH and NSF.

Who Must Comply

Undergraduate and graduate students who are supported by the NIH and NSF to conduct research and/or are working on NIH- or NSF-funded research must receive instruction in RCR. Faculty research advisors are strongly encouraged to be involved with both formal and informal student instruction in RCR so that they can serve as effective mentors to their students.


NIH and NSF policies both mandate instruction in RCR as part of the requirements for research funding. Therefore, St. John Fisher University will not release grant funds until the PI/PD has certified that all required RCR training has been completed.


PIs/PDs have the primary responsibility for complying with RCR training requirements on their awards and for providing instruction—either directly or indirectly—to the students involved in the sponsored research grant, including those students who are working directly with a co-PI/PD. The OSPFR, in consultation with the OSPFR Advisory Board, department chairs, and deans, is responsible for ensuring that the training modules meet funding agency standards.

NIH only: New (Type 1) applications must include a training plan for instruction in RCR. Renewal (Type 2) applications must also describe changes in formal instruction over the past project period and any revisions to be made for the future that addresses weaknesses in the current RCR curriculum.

NSF only: Proposals require the Authorized Organization Representative (AOR) to complete a certification that the institution has an RCR plan in place. While the actual training plans do not need to be included in the proposal, they are subject to review upon request.

The detailed plan for RCR training must address the following topics:

  • Responsible authorship and publication
  • Collaborative research, including collaborations with industry
  • Conflicts of interest—personal, professional, and financial
  • Data management, sharing, and ownership
  • Financial responsibility
  • Mentor/mentee responsibilities and relationships
  • Peer review
  • Plagiarism
  • Research misconduct
  • Reproducibility of research results
  • Research, ethics, and society
  • Communicating with the public
  • Presentation of research findings

Additional discipline-specific topics may include:

  • Research involving human subjects
  • Using animal subjects in research
  • Safe laboratory practices

NIH guidelines require students to receive substantive face-to-face instruction in RCR, with a preference for a series of programs or seminars rather than a one-day class or workshop. The Fisher online RCR course (offered by the CITI program) will only partially satisfy NIH guidelines; online modules must be coupled with at least eight hours of face-to-face instruction.

The online CITI course on its own will satisfy NSF guidelines.


Each student must successfully complete all of the required elements of the RCR training as outlined in this policy and sponsor requirements. Successful RCR instruction will be completed through one or more of the following:

Online RCR Course (offered by the CITI program)
Face-to-face instruction (one-on-one or in a group setting)

PIs/PDs must certify on the Responsible Conduct of Research (RCR) Documentation Form that the student has received RCR training that meets the research sponsor's specifications. The completed document will be submitted to the OSP, where it will be kept on file.

Approved June 2019
Next Review Fall 2023