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Compliance with Federal Responsible Conduct of Research (RCR) Training Requirements

  • Responsible Office: Division of Research Compliance, Research and Innovation
  • Current Approved Version: 10/03/2019
  • Policy Type: Administrative

Policy Statement and Purpose

National Science Foundation (NSF) Requirements

Since January 4, 2010, NSF has required the completion of responsible conduct of research (RCR) training for all undergraduate students, graduate students, and postdoctoral researchers paid by NSF to conduct research. 

At the time of proposal submission, each principal investigator (PI) must certify that all undergraduate students, graduate students, and postdoctoral researchers to be paid by their NSF award will complete a Virginia Commonwealth University program of training in RCR.  

NSF requires that the completion of RCR training be documented. 

See the “Policy Specifics and Procedures” section of this policy for more information

United States Department of Agriculture, National Institute of Food and Agriculture (USDA NIFA) Requirements

Since April 2013, USDA NIFA has required the completion of RCR training by all individuals paid from a USDA NIFA award, including but not limited to, PIs, co-investigators, undergraduate students, graduate students, postdoctoral researchers, and any staff members.

USDA NIFA views acceptance of the award as assurance that the RCR training requirement will be satisfied. 

USDA NIFA requires that the completion of RCR training be documented. 

See the “Policy Specifics and Procedures” section of this policy for more information. 

National Institutes of Health (NIH) Requirements

Since January 25, 2010, NIH has required instruction in RCR for all trainees, fellows, participants, and scholars who receive support through any NIH training grant, career development award (individual or institutional), research education grant, or dissertation research grant. This requirement applies to the following programs: D43, D71, F05, F30, F31, F32, F33, F34, F37, F38, K01, K02, K05, K07, K08, K12, K18, K22, K23, K24, K25, K26, K30, K99/R00, KL1, KL2, R25, R36, T15, T32, T34, T35, T36, T37, T90/R90, TL1, TU2, and U2R. The requirement also applies to any other NIH-funded programs supporting research training, career development, or research education that require instruction in RCR as stated in the relevant funding opportunity announcements or awards. 

The NIH provides comprehensive guidance regarding frequency of RCR instruction at grants.NIH.gov: 

Reflection on responsible conduct of research should recur throughout a scientist’s career: at the undergraduate, post-baccalaureate, predoctoral, postdoctoral, and faculty levels. Institutional training programs and individual fellows/scholars are strongly encouraged to consider how to optimize instruction in responsible conduct of research for the particular career stage(s) of the individual(s) involved. Instruction must be undertaken at least once during each career stage, and at a frequency of no less than once every four years. It is highly encouraged that initial instruction during predoctoral training occurs as early as possible in graduate school. Individuals at the early career investigator level (including mentored K awardees and K12 scholars) must receive instruction in responsible conduct of research at least once during this career stage. Senior fellows and career award recipients (including F33, K02, K05, and K24 awardees) may fulfill the requirement for instruction in responsible conduct of research by participating as lecturers and discussion leaders. To meet the above requirements, instruction in responsible conduct of research may take place, in appropriate circumstances, in a year when the trainee, fellow or career award recipient is not actually supported by an NIH grant.

At the time of proposal submission, each PI must certify that all individuals to be supported by an NIH training grant, career development award, research education grant, or dissertation research grant will complete an appropriate program in RCR in accordance with the NIH guidelines. 

Responsible Conduct of Research Education

This policy treats RCR education and RCR Training as two different processes. RCR education requirements are administered at the program level, and may be program specific. RCR education requirements represent VCU’s commitment to conduct responsible and ethical research at VCU.

RCR education at VCU follows NIH best practices. RCR education should include participant discussion and small-group discussions about case studies. Online courses should be viewed as a supplement to face-to-face instruction, and generally should not be considered sufficient as the sole means of providing RCR education at VCU.

Responsible Conduct of Research (RCR) Education Versus raining

This policy treats RCR education and RCR training as two different processes. 

RCR education requirements are administered at the program level and may be program-specific. 

RCR education at VCU follows NIH best practices. RCR education should include participant discussion and small-group discussions about case studies. Online courses should be viewed as a supplement to face-to-face instruction and generally should not be considered sufficient as the sole means of providing RCR education at VCU. 

RCR training is intended to meet NSF and USDA NIFA compliance standards and is tracked by the Division of Research Compliance. 

With respect to frequency, VCU requires RCR training once during a specific career stage (e.g., undergraduate, graduate, postdoctoral). 

VCU RCR courses that satisfy federal RCR requirements can be found here:  http://www.research.vcu.edu/responsible_conduct/rcr_courses.pdf.

Noncompliance with this policy may result in disciplinary action up to and including termination. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.

Who Should Know This Policy

All individuals involved with NSF grants, USDA NIFA grants, or NIH training grants are responsible for knowing this policy and familiarizing themselves with its contents and provisions.

Definitions

RCR Education

RCR education is administrated at the program level and is program-specific. RCR education requirements represent VCU’s commitment to conduct responsible and ethical research at the university.

RCR Training

RCR training is intended to meet NSF and USDA NIFA compliance standards and is tracked by the Division of Research Compliance.

Contacts

The Office of Vice President for Research and Innovation (OVPRI) officially interprets this policy. The OVPRI is responsible for obtaining approval for any revisions as required by the policy Creating and Maintaining Policies and Procedures through the appropriate governance structures. Please direct policy questions to the senior research compliance analyst in the Division of Research Compliance.

Policy Specifics and Procedures

Tracking NSF RCR Training

The Division of Research Compliance monitors compliance with the NSF RCR training requirement using a combination of reports and completed NSF/USDA NIFA RCR Training Completion Forms. 

Each semester, the Division of Research Compliance obtains a list of all individuals paid from active NSF accounts. If the Division of Research Compliance has no evidence that the paid individual has completed the required NSF RCR training, the office follows up with the respective PI regarding appropriate next steps.  

If the undergraduate student, graduate student, or postdoctoral researcher paid by NSF is unable to complete in a timely manner any of the courses that appear on the VCU RCR Course Matrix, then an alternative plan of study may be devised after consultation with the Division of Research Compliance.

In the event that an undergraduate student, graduate student, or postdoctoral researcher paid by NSF fails to complete the required RCR training, the salaries and/or wages along with any associated fringe benefits for that individual must be removed from the NSF-funded project. The PI’s program or department is responsible for covering any salary, wages, and fringe benefits determined unallowable as a result of noncompliance with this policy.

Tracking USDA NIFA RCR Training

The Division of Research Compliance monitors compliance with the USDA NIFA RCR training requirement using a combination of reports. 

Each semester, the Division of Research Compliance obtains a list of all individuals paid from active USDA NIFA accounts. If the Division of Research Compliance has no evidence that the paid individual has completed the required USDA NIFA RCR training, the office follows up with the respective PI regarding appropriate next steps.  

In the event that an individual paid by USDA NIFA fails to complete the required RCR training, the salaries and/or wages along with any associated fringe benefits for that individual must be removed from the USDA NIFA-funded project. The PI’s program or department is responsible for covering any salary, wages, and fringe benefits determined unallowable as a result of noncompliance with this policy.

NIH RCR Education

The OVPRI does not track NIH RCR education. The responsibility for ensuring that the NIH RCR education requirement has been satisfied falls to the PI associated with the particular NIH training grant.

Forms

  1. NSF/USDA NIFA RCR Training Completion Form

Related Documents

  1. VCU RCR Course Matrix
  2. Responsible Conduct of Research
  3. NSF Responsible Conduct of Research (RCR) - https://www.nsf.gov/bfa/dias/policy/rcr.jsp
  4. USDA NIFA Responsible Conduct of Research (RCR) - https://nifa.usda.gov/responsible-and-ethical-conduct-research
  5. NIH Responsible Conduct of Research (RCR) - https://grants.nih.gov/grants/guide/notice-files/NOT-OD-10-019.html

Revision History

This policy supersedes the following archived policies:

Approval/Revision DateTitle
12/04/2014 Compliance with NSF and NIH Responsible Conduct of Research (RCR) Training Requirements
09/07/2016 Compliance with NSF and NIH Responsible Conduct of Research (RCR) Training Requirements

FAQ

1. Does a student or postdoctoral researcher being paid from my NSF/USDA NIFA grant only for the summer have to take RCR training?

Yes. All undergraduate students, graduate students, and postdoctoral researchers participating in the research project must complete RCR training regardless of the amount paid by the grant. Any non-VCU undergraduate students, graduate students, and postdoctoral researchers paid by NSF to conduct research at VCU must also complete RCR training in accordance with this policy.

2. Should I, the PI, wait until someone from the OVPRI contacts me to inform my undergraduate students, graduate students, and postdoctoral researchers of this requirement?

No. Please inform these individuals of the applicable RCR requirement as soon as they begin working on the grant, so that they can satisfy the requirement in a timely manner. Completing the requirement is a term and condition of the grant award.

3. My advisor says I must take an OVPR RCR course to meet degree requirements. Does the online CITI Responsible Conduct of Research course replace this requirement?

No. The online CITI Responsible Conduct of Research course can be used only to meet the NSF or USDA NIFA RCR training requirement.

4. My student completed an RCR course that is not listed on the VCU RCR Course Matrix – does it count?

Possibly. We will need additional information, such as a course syllabus, before making a determination. Please contact the senior research compliance analyst in the Division of Research Compliance regarding this question.