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Training Requirements – NSF, NIH, USDA
National Science Foundation (NSF)
At the time of proposal submission, the researcher’s institution must certify via its authorized representative that it has a plan to provide training and oversight to all researchers, regardless of career stage, who are supported by funds from an NSF grant. It is not required to submit a training plan as a part of a proposal application, but the funding agency may request it at any time. The NSF does not prescribe specific methods to meet RCR training requirements, instead leaving it up to the institution to either utilize existing training resources or to develop new pedagogical methods or content to meet training needs.
The training requirement applies to anyone receiving support from the grant, including PIs, key personnel, and subawardees. Anyone listed on the grant, even if they do not directly receive funds from the grant, are required to complete RCR training. The institutional training plan must be in place at the time of the proposal, but the actual training of individuals can take place at a later time, as long as that expectation is listed in the institutional training plan. The online course available through the Collaborative Institutional Training Initiative (CITI) (www.citiprogram.org) satisfies the NSF RCR training requirement.
National Institutes of Health (NIH)
NIH RCR training requirements are detailed in their notice number NOT-OD-10-019 (https://grants.nih.gov/grants/guide/notice-files/NOT-OD-10-019.html) from 2011. The notice defines responsible conduct of research as “the practice of scientific investigation with integrity. It involves the awareness and application of established professional norms and ethical principles in the performance of all activities related to scientific research.” Their policy states that “all trainees, fellows, participants, and scholars receiving support through any NIH training, career development award (individual or institutional), research education grant, and dissertation research grant must receive instruction in responsible conduct of research.”
The NIH recognized that online courses can be a good supplemental resource, but that RCR training should involve more comprehensive didactic coursework with a focus on face-to-face training and small group discussions. Faculty should be directly involved in RCR instruction, in both formal and informal capacities, and those with the proper foundational knowledge and career stage should be prepared to act as mentors. The policy also states that there should be at least 8 contact hours for training, and training should be completed for every career stage, or at least every four years.
United States Department of Agriculture (USDA)
Per USDA policy 2 CFR Part 422, any institution completing research funded by the USDA must “foster an atmosphere conducive to research integrity, bear primary responsibility for prevention and detection of research misconduct, and maintain and effectively communicate and train their staff regarding policies and procedures”. The institution affirms as part of the acceptance of the award that they will comply with this policy. The awardee does not have to submit an RCR plan as part of the application, but they must provide documentation supporting compliance with the training requirement at the request of the funder.
USDA’s National Institute of Food and Agriculture (NIFA) updated their RCR requirements effective June 30, 2017 (https://nifa.usda.gov/responsible-and-ethical-conduct-research). In the event an application to NIFA results in an award, the Authorized Representative (AR) assures, through acceptance of the award, that the institution will comply with the above requirements. Award recipients shall, upon request, make available to NIFA the policies, procedures, and documentation to support the conduct of the training.
For more information regarding training requirements or if you have any questions, please contact Jillian Byrne-Sweeney at 940-369-8374 or firstname.lastname@example.org.