Responsible Conduct of Research Compliance Policy

Responsible Conduct of Research Compliance Policy
Type of Policy
Administrative
s1polics Tue, 12/15/2015 - 15:16
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Reason for Policy

Georgia Tech’s Responsible Conduct of Research (RCR) Compliance Policy is intended to comply with the requirements of the National Science Foundation’s (NSF) implementation of the requirements of Section 7009 of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science Act (42 U.S.C. 1862o–1) found in the NSF Proposal and Award Policies and Procedures Guide, the National Institutes of Health (NIH) requirements found in NOT‐OD‐10‐019, and the U.S. Department of Agriculture (USDA) National Institute of Food and Agriculture (NIFA) program’s RCR training requirements. The applicability criteria contained within this Policy (see below) may expand to cover other groups of researchers and sponsors in the future. RCR is defined by the NIH “…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.”

Policy Statement

It is the policy of the Georgia Institute of Technology that undergraduate students, graduate students, and postdoctoral researchers on covered awards who are engaged in research shall receive formal instruction in ethical considerations and decision‐making in Responsible Conduct of Research (RCR) that is appropriate for their disciplines and career stage. Faculty, staff, and other members of the Georgia Tech community must complete RCR training as well if the sponsor of their research imposes the requirement.

It is the responsibility of the Principal Investigator/Project Director (PI/PD) of covered awards (see Applicability below) to ensure that all applicable research team members are informed of the requirement and that the requirement has been met. In the case of the NSF Graduate Research Fellowship Program (GRFP), these responsibilities will be shared between the graduate advisor and the Coordinating Official in the Fellowship Office. Moreover, it is the PI’s responsibility to provide appropriate mentoring through discussions of RCR topics and through oversight of the research project.

Scope

The RCR Compliance Policy requires that students, postdoctoral researchers, faculty, and staff receiving research funds or who participate in research activities funded by Georgia Tech’s President’s Undergraduate Research Award Program (PURA) and certain covered awards (see applicability below) shall engage in a program of study in RCR that includes some or all of the following elements:

  • Authorship and publication
  • Collaborative research, including collaborations with industry
  • Conflicts of interest including personal, professional, and financial
  • Data acquisition, management, sharing, ownership and reporting
  • Mentor/mentee responsibilities and relationships, including how to support a respectful, inclusive environment and prevent harassment
  • Peer review
  • Policies regarding human subjects in research
  • Policies regarding live vertebrate animal subjects in research
  • Policies regarding safe laboratory practices
  • Research misconduct and policies for handling research misconduct
  • The scientist and engineer as a responsible member of society, and the environmental and societal impacts of scientific research

Applicability
This Policy is intended to meet the RCR training requirements of federal funding agencies and other sponsors. The applicability criteria contained within this Policy may expand to cover other groups of researchers and sponsors in the future.

This Policy covers:

GT PURA ­­– This Policy applies to all students who participate in Georgia Tech’s President’s Undergraduate Research Award (PURA) Program.

NSF ­­– This Policy applies to all undergraduate students, graduate students, and postdoctoral researchers, whether as an employee, Graduate Research Assistant (GRA), or other trainee, funded by new proposals submitted, or due, on or after January 4, 2010, to conduct research; it excludes, for example, conference, symposium, workshop, and travel proposals. The Policy also applies to students funded by the NSF GRFP Fellowship.

NIH ­­– This Policy applies to the NIH programs listed here. All undergraduate students, graduate students, and postdoctoral researchers funded by an NIH training grant, a career development award (individual or institutional), a research education grant, a fellowship, or a dissertation research grant must receive RCR instruction, with the exception of those funded by the K99/R00 program. For the K99/R00 program, only the PI (fellow) of the project is required to complete the RCR training.

USDA NIFA ­­– This Policy applies to all researchers funded by the USDA National Institute of Food and Agriculture (NIFA) program, including the principal investigator, other faculty members, students, postdocs, and any staff participating in the research project.

Policy Terms
RCR

Responsible Conduct of Research

Procedures

5.1 Training Requirements by Funding Source and Career Stage

President's Undergraduate Research Awards (PURA) Program
All undergraduate students participating in Georgia Tech’s PURA Program must complete the online RCR training from the Georgia Tech approved vendor. (http://www.rcr.gatech.edu/pura).

The mentors of students funded by the PURA Program are strongly encouraged to provide discussion-based training opportunities for these students as well.

Undergraduate Students Funded by Covered NSF or NIH Awards
All undergraduate students paid in whole or in part from covered awards funded by NSF or NIH must complete both: (1) online RCR training from the Georgia Tech approved vendor and (2) in-person RCR training.

Applicable NSF-funded undergraduates must complete at least 1 hour of discussion-based RCR instruction; it is strongly encouraged that this instruction be focused on the topic of research misconduct.  NIH-funded undergraduates must complete at least 8 hours of discussion-based (“in-person”) RCR instruction.  At the discretion of the PI or School, applicable undergraduate students shall fulfill the discussion-based (“in-person”) RCR training requirement by either:

  • Participating in OSP approved RCR training events (www.rcr.gatech.edu/workshops); or
  • Participating in educational events that the PI or School has deemed appropriate for RCR training, which can include regularly scheduled meetings or discussions involving the research team that address RCR topics; or it can involve a class, seminar, or other interactive approach developed by the School or PI that addresses RCR topics.‡

UNDERGRADUATE
IN-PERSON RCR TRAINING
REQUIREMENT

Funding Source and Hours Required

Training Options

NSF - 1 HOUR

  • OSP approved RCR Training Events
  • Research Team Meetings‡
  • Other events approved by the PI or School‡

NIH - 8 HOURS

‡ Documentation of this form of in-person training must be maintained in the project file by the PI.  All other training will be documented in either the Research Administration Education & Compliance training system or in Banner.

NSF-Funded or NIH-Funded Master’s Students
All master’s students paid in whole or in part from covered awards funded by NSF or NIH must complete both: (1) online RCR training from the Georgia Tech approved vendor and (2) in-person RCR training.

Applicable NSF-funded master’s students must complete at least 2 hours of discussion-based RCR instruction.  NIH-funded master’s students must complete at least 8 hours of discussion-based RCR instruction. At the discretion of the PI or School, applicable master’s students shall fulfill the “in-person” requirement by either:

  • Participating in OSP approved RCR training events (www.rcr.gatech.edu/workshops);  or
  • Registering through Oscar and successfully completing an approved RCR course  (http://rcr.gatech.edu/rcr-courses); or
  • Participating in educational events that the PI or School has deemed appropriate for RCR training, which can include regularly scheduled meetings or discussions involving the research team that address RCR topics; or it can involve a class, seminar, or other interactive approach developed by the School or PI that addresses RCR topics.‡

MASTER’S STUDENT
IN-PERSON RCR TRAINING
REQUIREMENT

Funding Source and Hours Required

Training Options

NSF - 2 HOURS

  • OSP approved RCR Training Events
  • Approved RCR course                        
  • Research Team Meetings‡
  • Other events approved by the PI or School‡

NIH - 8 HOURS

‡ Documentation of this form of in-person training must be maintained in the project file by the PI.  All other training will be documented in either the Research Administration Education & Compliance training system or in Banner. 

NSF-Funded or NIH-Funded Doctoral Students
Doctoral students paid in whole or in part from covered awards funded by NSF or NIH must adhere to the training requirements delineated within the GT RCR Academic Policy for Doctoral Students (http://www.rcr.gatech.edu/doctoral-policy/).

NSF-Funded or NIH-Funded Postdoctoral Researchers
All postdoctoral researchers paid in whole or in part from covered awards funded by NSF or NIH must complete both: (1) online RCR training  from the Georgia Tech approved vendor and (2) in-person RCR training.

Applicable NSF-funded postdoctoral researchers must complete at least 4 hours of discussion-based RCR instruction and NIH-funded postdoctoral researchers must complete at least 8 hours of discussion-based RCR instruction in order to satisfy the in-person training requirement. At the discretion of the PI or School, applicable postdoctoral researchers shall fulfill the “in-person” requirement by either:

  • Participating in educational events that the PI or School has deemed appropriate for RCR training, which can include regularly scheduled meetings or discussions involving the research team that address RCR topics; or it can involve an interactive approach developed by the School that addresses RCR topics.‡

POSTDOCTORAL
IN-PERSON RCR TRAINING
REQUIREMENT

Funding Source and Hours Required

Training Options

NSF - 4 HOURS

  • OSP approved RCR Training Events
  • Receive permission to attend PHIL 6000
  • Research Team Meetings‡
  • Other events approved by the PI or School‡

NIH - 8 HOURS

‡ Documentation of this form of in-person training must be maintained in the project file by the PI.  All other training will be documented in either the Research Administration Education & Compliance training system or in Banner.

USDA NIFA-Funded Students, Postdoctoral Researchers, Faculty, and Staff
All researchers funded through the National Institute of Food and Agriculture (NIFA) program, including the principal investigator, other faculty members, students, postdocs, and any staff participating in the research project (defined as those who are funded by the project), must complete an online RCR training from the Georgia Tech vendor.

The PIs of projects sponsored by NIFA are strongly encouraged to provide discussion-based training opportunities for their research team as well.

5.2 Re-training Requirements

Change of Career Stage
Any applicable student who received RCR training during one career stage at Georgia Tech (for example, as an undergraduate) and is required to complete RCR training after changing to a different career stage at the Institute (for example, by becoming a master’s student) must at a minimum complete any additional RCR training requirements associated with the latter career stage. A postdoctoral researcher in this circumstance who received RCR training as a doctoral student at Georgia Tech must complete at least 1 additional “in-person” training hour. Applicable students and postdocs must also adhere to any re-training requirements imposed by their funding source. 

NIH-Funded Students or Postdoctoral Researchers
According to the NIH, “Reflection on responsible conduct of research should recur throughout a scientist’s career: at the undergraduate, post-baccalaureate, predoctoral, postdoctoral, and faculty levels ... Instruction must be undertaken at least once during each career stage, and at a frequency of no less than once every four years.”

The PIs of covered NIH projects are required to develop an RCR training plan that addresses the re-training requirement and ensure that their trainees adhere to that plan.

5.3 Deadline for Training Completion

Online Training Deadline

The online training requirement described within this Policy, must be successfully completed within ninety [90] days of first being appointed to a covered award. Even if it imposes a shorter deadline, the online training requirement must be completed before an applicable person graduates or otherwise leaves the Institute.

In-Person Training Deadline
The “in-person” RCR training requirements described within this Policy must be completed within the first year of the appointment to the covered award. Even if it imposes a shorter deadline, the in-person training must be completed before the applicable person graduates or otherwise leaves the Institute.

A doctoral student funded by a covered award must follow the in-person completion deadline delineated in this Policy unless the “in-house” RCR course required by their home academic unit is not offered during the first year of the student’s doctoral program. However, if an applicable doctoral student is unable to complete the required in-person RCR training prior to graduating or leaving the Institute, the student must, at a minimum, have an RCR exit interview with the PI/advisor.

5.4 Pre-Award Procedures

RCR Instruction Plan
Compliance with the requirements for providing RCR instruction is a responsibility of the PI.  As such, the PI for covered proposals, with the exception of the PI for NSF GRFP Fellows, shall complete the RCR Project Plan Addendum to the Sponsored Programs/Research Proposal Authorization Routing Form at the time an applicable proposal is submitted.* This Plan should indicate which instruction method(s) will be used for those individuals who are appointed to the project and are required to complete RCR training.  It shall become part of the project file in the Office of Sponsored Programs (OSP). 

* The training requirement for covered proposals will be flagged "Yes" in the OSP Oracle Database under T&C Ethics/RCR Training and in the Research Portal under "Effort on My Funds". 

5.5 Post-Award Procedures

Online Training
The Office of Grants & Contracts Accounting will prepare reports of applicable students, postdoctoral researchers, faculty, and staff that are paid from applicable projects and will check these individuals against CITI records.  PIs, the School, or the Fellowship Office will be notified of any non‐compliance of those who are required to complete CITI training.

 

Documentation of online RCR training is accomplished through the CITI Program; records will be maintained in the Research Administration Education & Compliance training system.

In-Person Training
Documentation of in-person training that has been taken to satisfy the RCR Compliance Policy is the responsibility of the PI unless the training has been completed through an OSP approved RCR training event (http://www.rcr.gatech.edu/workshops) or through an approved RCR course (http://www.rcr.gatech.edu/rcr-courses).  OSP approved RCR training events will be documented in the Research Administration Education & Compliance training system; RCR courses will be documented in Banner.

Training Certification
It is the PI’s responsibility to certify on an annual basis that all students and postdoctoral researchers funded by the project are in compliance with RCR training requirements. The Annual RCR Certification must be made via the OSP Deliverable System.

Responsibilities

The Principal Investigator (PI)
The PI is responsible for:

  • Filling out the RCR Project Plan Addendum to the Sponsored Programs/Research Proposal Authorization (as described in 5.4);
  • Notifying the research team of any applicable RCR training or re-training requirements;
  • Ensuring that the research team completes the RCR training;
  • Retaining records in the project file (as described in 5.5);
  • Certifying to OSP on an annual basis that the RCR training has been completed (as described in 5.5); and
  • If a covered NIH project, preparing a plan to address the re-training requirements (as described in 5.3).

Office of Sponsored Programs (OSP)
The OSP is responsible for:

  • Notifying PIs about the RCR training requirements via terms and conditions in the project initiation package;
  • Retaining records of online RCR training completions;
  • Notifying trainees, staff, and/or PIs of  non-compliance of online RCR training requirements; and
  • Retaining records of attendance at OSP- approved RCR workshops and events.

Coordinating Official (Fellowship Office)
The Coordinating Official for the Fellowship Office is responsible for:

  • Advising NSF GRFP Fellows on RCR policies and training requirements;
  • Communicating with the RCR Program about new GRFP fellows;
  • Working with the GRFP Fellow’s graduate advisor to ensure that the training is completed;
  • Working with the GRFP Fellow’s graduate advisor to obtain the necessary verifications required by NSF which confirm that all responsibilities have been fulfilled;
  • Certifying Satisfactory Academic Progress;
  • Working in coordination with the PI and the RCR Program on the annual RCR certification that is submitted to OSP;
  • Retaining records of in-person training completed outside of OSP approved events or approved RCR courses.
Enforcement

Students and Postdoctoral Researchers
Non‐compliance with the training completion deadlines specified in this Policy on the part of any employed student or postdoctoral researcher may result in the termination of employment and shall result in the disallowance of salary and any associated expenses charged to the sponsored award.

Non-compliance on the part of any NSF Graduate Research Fellow shall result in the failure to certify the Fellow’s Satisfactory Academic Progress and may result in the termination of the Fellowship.

Faculty and Staff
Non-compliance with the training completion deadlines specified in this Policy by faculty or staff on a USDA NIFA award shall result in the disallowance of salary and any associated expenses charged to the sponsored project.

Non-compliance by the PI on a USDA NIFA award may also result in the removal of the PI from the project and the appointment of a replacement PI.

Policy History
Revision Date Author Description
01-01-2016 OSP Compliance Updates