Requirements for Ethics Training on NSF Grants
The National Science Foundation (NSF) has established requirements for institutions to provide training and mentoring in regard to the Responsible Conduct of Research (RCR) to students and post-doctoral researchers who are employed on grant projects submitted for funding after January 4, 2010. The institution must have a training plan available upon request for students and post-docs, and all new applications to NSF must include a mentoring plan if any post-docs will be employed.
Summary of UNI requirements outlined below (for quick reference):
- All students or post-docs being paid on NSF grants funded beginning January, 2010 must be trained in the Responsible Conduct of Research (RCR) within 2 weeks of their appointment to the project.
- This requirement can be fulfilled by the student taking an online course through the CITI Training Program page.
- Training certificates must be emailed to firstname.lastname@example.org or sent to OSP at 213 East Bartlett Hall.
- All NSF grant applications that include post-doctoral researchers must contain a plan for mentoring them in RCR.
UNI procedures for meeting the NSF requirements
There are two requirements that the institution must comply with.
The post-doc mentoring requirement is for investigators submitting NSF grants after January 4, 2010. All grants must now include a supplementary document describing the plan for mentoring any post-doctoral researchers to be employed on the project. This requirement does not apply to mentoring students, only post-docs. More information is available from your OSP grant specialist, from the NSF policy documents (see link above), and probably in the NSF program solicitation to which you are responding.
The training requirement is that the institution must have a plan for ensuring that all students and post-docs employed on NSF grants receive training in the Responsible Conduct of Research (RCR). Investigators are not required to report on the training directly to NSF, but institutions must be able to provide the plan upon request. UNI's procedures for addressing this requirement are as follows.
- Principal investigators (PI)s on all NSF grants submitted beginning in January, 2010 must ensure that all undergraduates, graduate students and post-doctoral researchers to be employed on a project funded at least in part by an NSF grant or subcontract receive basic training in RCR within 2 weeks of their appointment to the project. The requirement includes any students or post-docs being paid from matching funds for NSF projects.
- One basic option to comply with this requirement is for the student or post-doc to complete an RCR online tutorial that is hosted by the Collaborative Institutional Training Initiative (CITI), based at the University of Miami. This tutorial can be accessed by anyone affiliated with UNI through the CITI Training Program page (see link below).
- All PIs are encouraged to take the course themselves and to consider it for all other faculty and staff employed on their projects, but it is only required at this time for students or post-docs being paid on NSF projects.
- Other alternatives for training in RCR are acceptable if the PI can show that the source is legitimate and content comparable to that of the CITI program.
- Passing scores on the CITI RCR module quizzes will be required to obtain a certificate from the CITI program that the individual received the training. Upon completion, the trainee should print the certificate or save it to his/her computer, and provide a copy of it to the PI.
- Training certificates for students (and any others receiving the training) must be kept on file by the PI. In addition, copies must be sent to the Director of Research Services in the Office of Sponsored Programs (email@example.com). OSP will file these in NSF grant files for auditing purposes. The PI will be responsible for sending certificates throughout the life of the project whenever new students are added.
- If the certificate is not in the grant file within 2 weeks of the student's first day employed, grant funding to support the student's or post-doc's employment will be suspended as of the next pay date, and any expenses incurred beyond the fourth week of employment will therefore be the responsibility of the department until the certificate is received by OSP.