Policy on Responsible Conduct of Research (RCR) for NSF grantees

In order to comply with recent federal legislation and regulations, the UND has established a program for mentoring undergraduates, graduate students, and post-doctoral fellows who are supported by the National Science Foundation in the Responsible Conduct of Research (RCR).

Background

Section 7009 of the America COMPETES Act of 2007 (America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education and Science) directed that the National Science Foundation require institutions receiving financial assistance from the Foundation for science and engineering research or education to implement mentoring and training in the responsible and ethical conduct of research for undergraduate and graduate students as well as postdoctoral researchers.

In responding to this requirement, the NSF published a revision to its NSF Proposal & Award Policies and Procedures Guide requiring that beginning January 4, 2010, institutions must certify, at the time of proposal submission, the institution has a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduates, graduate students, and postdoctoral researchers who participate in NSF-funded projects.

Purpose

The purpose of this document is to outline a plan for implementing NSF’s requirements for providing training to undergraduate and graduate students and postdoctoral researchers in the responsible and ethical conduct of research.

Policy Statement

All University of North Dakota undergraduate and graduate students as well as postdoctoral researchers who participate in NSF-funded research or educational projects must fulfill educational requirements related to the responsible and ethical conduct of research.

All members of the UND research community, to include students and postdoctoral researchers, are expected to adhere to the highest ethical and professional standards as they pursue research and scholarly activities. In so doing, it requires the vigilance of all members engaged in research and scholarly endeavors to comply with the legal, regulatory, and ethical requirements established by the University, regulatory agencies, funding sources and professional organizations.

The Office of Research Integrity (ORI) in the U.S. Department of Health and Human Services is the federal agency charged with the responsibility of oversight for the responsible conduct of research. The ORI encourages researchers to make a special effort to understand, discuss, and teach others about the responsible conduct of research. It is understood that RCR can be taught and learned in many ways and that standards can vary from discipline to discipline. For this reason, it is the intent of the RCR Education Program at UND to provide flexibility in its content and delivery modes in such a way that it addresses the specific needs, issues and concerns of various target audiences among numerous disciplines.

RCR Content

• Research Misconduct
• Conflict of Interest and Conflict of Commitment
• Human Subjects
• Research Involving Animals
• Data Acquisition, Management, Sharing and Ownership
• Publication Practices and Responsible Authorship
• Mentor/Trainee Responsibilities
• Peer Review
• Collaborative Science

Plan

The UND RCR training program will consist of three parts.

Part 1.

All principal investigators (PIs) with NSF awards will be required to meet with representatives of the Division of Research to discuss the mentorship responsibilities of the PIs. Initially, all current awardees will be involved. However, in the future meetings will be held with awardees upon notice of the award from NSF. The meeting will focus on the topics to be covered in the RCR content and the responsibility of the PIs to appropriately mentor their students and postdoctoral fellows.

Part 2.

All undergraduate and graduate students, and postdoctoral fellows who will be working on an NSF-funded award will be required to complete the Collaborative Institutional Training Initiative (CITI) courses in the RCR content sections relevant to their research immediately upon joining a laboratory. For example, all participants will be required to complete the Research Misconduct, Conflict of Interest and Commitment, Data Acquisition, and Mentor/Trainee Responsibilities. Participants will be required to take those other courses which are relevant to their specific research projects as determined by their mentor. It is expected that completing the CITI courses will be part of the normal orientation process of all new students and fellows in a laboratory. New students and fellows will not be allowed to be paid from an NSF grant until they have completed the CITI courses required for their research.

Part 3.

All undergraduate and graduate students, and postdoctoral fellows who will be working on a NSF-funded award will be required to attend at least one ethics-related workshop each year sponsored by the University of North Dakota. The workshops will consist of internal or external content experts discussing one or more of the topics listed in the RCR Content section above.

Assessment

The goals of the RCR Education program are to:

– Serve as a catalyst for the questioning of decisions, practices and processes related to the responsible conduct of research with the objective of arriving at better informed decisions.

– Promote skill development by:

• Recognizing and defining ethical issues
• Identifying relevant stakeholders and socio-technical systems
• Collecting relevant data about stakeholders and systems
• Understanding relevant stakeholder perspectives
• Identifying value conflicts
• Constructing viable alternative courses of action or solutions and identifying constraints
• Assessing alternatives in terms of consequences, public defensibility, institutional barriers, etc.
• Engaging in reasoned dialogue or negotiations
• Revising options, plans or actions
• Collecting relevant data about stakeholders and system accountability

The Division of Research and Economic Development will be responsible for ensuring compliance with this policy. The Division will monitor attendance at all required programming. Failure to complete the necessary requirements of this policy will result in suspension from working on the award for a student or postdoctoral fellow and possible suspension of spending on the award until requirements are met. Any charges incurred during the time of the suspension of the award will not be allowed to be charged to the grant, but will have to be covered from another funding source.

— Barry Milavetz, Associate VP for Research.