Federal requirements require Responsible Conduct of Research (RCR) training for scholars funded by NSF, USDA and NIH. Those requirements are detailed below:
NSF - The recent America COMPETES Act includes a requirement that beginning with proposals submitted on or after January 4, 2010, all undergraduate students, graduate students, and postdoctoral researchers" who will be supported by National Science Foundation (NSF) to conduct research" receive training in the Responsible Conduct of Research (RCR).
NIH - NIH requires that all trainees, fellows, participants, and scholars receiving support through any NIHtraining, career development award (individual or institutional), research education grant, and dissertation research grant must receive instruction in responsible conduct of research. This policy will take effect with all new and renewal applications submitted on or after January 25, 2010, and for all continuation (Type 5) applications with deadlines on or after January 1, 2011.
USDA - Effective for awards subject to the February 2013 Research Terms and Conditions, the U.S. Department of Agriculture (USDA) National Institute of Food and Agriculture (NIFA) has mandated that program directors, faculty, undergraduate students, graduate students, postdoctoral researchers, and any staff participating in the research project receive appropriate training and oversight in the responsible and ethical conduct of research (RCR). Any award issued after February 1, 2013 must comply with this requirement.
RCR is comprised of 9 topic areas:
Acquisition, Management, Sharing and Ownership of Data
Conflict of Interest
Human Subject Protections
The CU RCR training program includes both interdisciplinary general and program-specific RCR content. The phased program is intended to provide quality training experiences while offering flexibility for the learner.
1. Basic training- Those covered individuals (described above) are required to complete an online RCR training program provided by the Collaborative Institutional Training Initiative (CITI).
This requirement must be completed within the first 12 months of support/employment/participation on the award (or earlier, at the discretion of the PI).
All covered individuals must complete basic training even if supported/employed less than 12 months.
Documentation of basic training: Documentation of completion of this component will be maintained by the ORC. Additionally, a completion certificate is available for printing via CITI. A copy of this certificate should be maintained by the individual completing the training and the PI. PI should attach this documentation to the RCR training documentation form he/she keeps on each covered individual.
2.Advanced training- Those covered individuals are also required to engage in an additional 5(NSF/USDA)/8(NIH) contact hours of discussion-based RCR training. These discussions will encompass both general and discipline-specific material. The 5/8 contact hours may include a variety of activities determined by the PI to be effective and engaging. The contact hours must include more than one topic area. Custom-designed workshops, forums, and classes, or existing classes and seminars offered by the college or department, and/or participation in external offerings may all be included. Plans may include encouragement to attend some of the RCR programs offered through the ORC, such as Research Integrity Brownbag discussions, RCR Workshops, Survival Skills and Ethics Workshops, and IRB or IACUC Training Programs. For an existing course or program to be suitable for fulfilling one of the training requirements, the PI must document that relevant topics from the above list are covered in the course/program.
This requirement must be completed in the first 24 months of support/employment on the award.
Documentation of advanced training: Documentation of completion of this component must be maintained by the covered individual and the PI (on the RCR training documentation form) and provided to the University and/or the funding agency upon request. This component will be implemented by PIs with the assistance of their college and department in a way that meets the particular needs of each unit.
Certificate Option /Demonstration of competency - This option may be made mandatory by the PI or college, if they so choose. After completing both the basic and advanced training components, covered individuals may demonstrate competency by participating in or writing a case study. The case study will show (a) awareness of the ethical dimensions of research in his/her area and (b) competency in working one's way to the other side of an ethical problem in a systematic, reflective and responsible way. A committee will evaluate a case-study related final product. Those who have a favorable evaluation will receive a certificate that could be a potentially valuable credential for a postdoctoral researcher or a person entering industry or academe as faculty researcher who would be working on federally supported research.
Retention of documentation- The completed RCR training documentation form with attachments (copy of online training certificate, case study, etc.) must be maintained by the PI for a period of three years after the conclusion of the award. Copies of case studies will be forwarded to ORC to serve as a resource for future RCR training.
The Office of Research Compliance will provide resources to support the program and its implementation by the PI. Resources available include:
Training opportunities for faculty involved in teaching RCR
ORC sponsored RCR workshops to complement college and departmental offerings
Individualized consultation and advice
Access to the CITI program
Teaching resources, such as slide shows and case studies, for RCR education
Online training modules
A list of upcoming RCR offerings available on campus
Frequently Asked Questions:
Q- What if an individual works on my grant for less than 12 months? Does he/she need to complete the basic RCR training? A- Yes. All covered individuals must complete basic RCR training.
Q - Does this plan need to be included with my proposal? A- For USDA and NSF, no. The institutional RCR plan is part of the institutional assurance and does not need to be included in the text of your proposal. However, a mentoring plan (NSF - section 7008) is required if you request support for a postdoc. A- For NIH, yes. See NIH guidance for more information. A template has been developed to assist you in drafting this part of your proposal.
Q - Is this the same training required for IACUC, IRB or IBC applications? A- No. While animal welfare and human subjects protections are RCR topics, the online IRB and IACUC training modules do not meet the requirement for discussion-based contact hours.
Q - Can training sessions/courses taken last year be applied to these requirements? A- This decision will be left to the discretion of the PI. If the PI believes the session is recent enough and relevant enough to meet the requirement, they should simply document it on the RCR training documentation form. CU will not define a training expiration period at this time. Again, this will be a decision left to the discretion of the PI.
Q- Are my summer REU students required to complete the RCR training? A - Based on the most recent REU information, NSF considers these students "supported" by NSF to conduct research. Therefore, they must complete the relevant phase(s) of the training program.