National Science Foundation Responsible and Ethical Conduct in Research Education Plan

Background

This plan was revised due to National Science Foundation (NSF) policy changes. In addition, the title of the plan was changed to be consistent with the NSF’s terminology of Responsible and Ethical Conduct in Research Education Plan (RECR).

The America COMPETES Act, signed into law in 2007, mandated training in the Responsible Conduct in Research (RCR). As a result, the NSF began requiring institutions to certify that they have an RCR plan and outline the training for individuals paid by NSF grants. This certification was effective for proposals submitted on or after January 4, 2010. For proposals submitted on or after July 31, 2023, this certification is replaced by one that expands the training requirement to faculty and other senior personnel and mandates that the training cover mentor training and mentorship.

Wake Forest University has required training in the responsible and ethical conduct in research for all undergraduate students, graduate students, and postdoctoral researchers paid by NSF grants resulting from proposals submitted on or after January 4, 2010. The types of activities, outlined below, depend on the role of the individual. NSF policy exempts individuals paid by conference, symposium, workshop, or travel grants. Principal Investigators (PIs) are responsible for ensuring that all research group members participate in the appropriate programs as required.

Please note that the CITI course in the responsible and ethical conduct in research is different from the CITI Human Subjects Research training course. Completing the CITI course in the responsible and ethical conduct in research does not satisfy the requirements for individuals working on research involving human subjects. Likewise, completing the CITI Human Subjects Research training course does not satisfy the responsible and ethical conduct in research education requirements.

Undergraduate Students

Applicability: All undergraduates paid on an hourly, or other, basis to assist faculty in their laboratories working on NSF- funded research projects, including those who are paid through a Research Experience for Undergraduates (REU) supplement during the summer, must complete an education program in the responsible and ethical conduct in research. PIs may also require that undergraduate research fellows in their laboratories complete the education program even if these students are not paid by an NSF grant.

Undergraduates meeting the criteria above should complete the on-line CITI course within 30 days of beginning to work on the grant. The modules required are discipline-specific: Biomedical Research, Social and Behavioral Research, Physical Sciences, and Humanities. Since most NSF PIs at WFU are in the Biology, Chemistry, Engineering, and Physics Departments, most students will complete the Physical Sciences module.

In addition to the on-line course, students are expected to attend a 2-hour workshop offered during summer. The workshop must be completed within the first year of grant-funded research. Students may not charge the time used to complete the training to the NSF grant, but PIs may use discretionary funds to pay for it.

If an undergraduate beginning work on an NSF grant does not complete on-line training within 60 days, all previous and future salary charges will be transferred to the PI’s discretionary funds.

Graduate Students

Applicability: NSF Graduate Research Fellows, graduate students paid on an hourly basis by an NSF grant or who have an NSF-supported assistantship must complete an education program in the responsible and ethical conduct in research.

Graduate students meeting the criteria above are required to participate in one 2-hour workshop that will be offered each semester. They must also complete the on-line CITI course within 30 days of beginning work on the grant. The modules required are discipline-specific: Biomedical Research, Social and Behavioral Research, Physical Sciences, and Humanities. Since most NSF PIs at WFU are in the Biology, Chemistry, Engineering, and Physics Departments, most students will complete the Physical Sciences module.

If a graduate student beginning work on an NSF grant does not complete on-line training within 60 days, all previous and future salary charges will be transferred to the PI’s discretionary funds.

Postdoctoral Researchers

Applicability: Postdoctoral researchers who are paid in full or in part by NSF grant funds must complete the on- line CITI course the responsible and ethical conduct in research within 30 days of beginning work on the grant. In addition, they are encouraged to attend the Introduction to the Responsible Conduct of Research workshop offered at Wake Forest Baptist Health or the 2-hour workshop for graduate students. This training should be supplemented through interactions with the PI as required by the postdoctoral researcher’s mentoring plan.

If a postdoctoral researcher beginning work on an NSF grant does not complete on-line training within 60 days, all previous and future salary charges will be transferred to the PI’s discretionary funds.

Senior Personnel, including PIs, Co-PIs, and Faculty Associates

Applicability: Faculty and staff who are senior personnel on an NSF grant that resulted from a proposal submitted or due on or after July 31, 2023 must complete the on-line CITI training. Senior personnel include PIs, Co-PIs, and Faculty Associates. All senior personnel, regardless of whether they will receive salary from the grant must complete this training before any new award will be set up by ORSP.

Responsibilities

Principal Investigator:

• Complete the CITI course
• Strive to ensure that undergraduates, graduate students, and postdoctoral researchers paid by an NSF grant complete the education requirements within 30 days of beginning work on the grant
• Lead by example; set standards in the laboratory

Co-Principal Investigators and other senior personnel:

• Complete the CITI course

Office of Research and Sponsored Programs:

• Certify to the existence of a RECR Education plan on NSF proposals
• Maintain the RECR education plan and RECR webpage
• Access course completion information for faculty, staff, and students who complete the CITI course
• Regularly receive a list from Payroll of individuals paid by NSF grants who are subject to RECR education requirements; compare this list to the list of those who have completed the various programs
• Certify at proposal submission that subawardee institutions have appropriate RECR education plans
• Ensure that the responsible and ethical conduct in research education requirement is included in all subawards, including those to international institutions, as appropriate
• Maintain a list of the in-person workshop attendees
• Schedule an in-person, 2-hour session in the responsible and ethical conduct in research for graduate students each semester
• Pay for the cost of the 2 -hour sessions in the responsible and ethical conduct in research for graduate students each semester
• Provide funding for half the cost of the 2-hour session in the responsible and ethical conduct in research for undergraduate students

Undergraduate Research and Creative Activities Center (URECA):

• Work with ORSP to schedule an in-person, 2-hour session in the responsible and ethical conduct in research for undergraduate students each summer
• Disseminate training requirements to faculty whose students will receive undergraduate research fellowships
• Provide funding to cover half the cost of the 2-hour in-person training session for undergraduate students

Financial Services:

• Will initiate the cost transfer of unallowable salaries when the required training is not completed

References

National Science Foundation website: http://www.nsf.gov/bfa/dias/policy/rcr.jsp