Responsible Conduct of Research Compliance Policy

Type of Policy: 
Administrative
Effective Date: 
January 2016
Last Revised: 
May 2017
Review Date: 
May 2020
Policy Owner: 
Sponsored Programs, Office of
Contact Name: 
Trudy M. Riley
Contact Title: 
Executive Director, Office of Sponsored Programs
Contact Email: 
Trudy.riley@osp.gatech.edu
Reason for Policy: 
Georgia Tech’s 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 Award and Administration Guide: Chapter IV, 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 trainees engaged in research at the undergraduate, graduate, and postdoctoral levels shall receive formal instruction in ethical considerations and decision‐making in Responsible Conduct of Research (RCR) that is appropriate for their disciplines and for the stage of their research careers. Faculty, staff, and other members of the Georgia Tech community will need to complete RCR training if the sponsor of their research imposes that requirement. It is the responsibility of the Principal Investigator/Project Director (PI) of covered projects (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:

  • Conflicts of interest (personal, professional, and financial)
  • Policies regarding the use of human subjects in research
  • Policies regarding the use of vertebrate animals in research
  • Laboratory safety, biohazard management, chemical safety, and polices regarding the use of radioisotopes and radiation sources in research
  • The responsibilities and relationships of mentors and mentees
  • Collaborative research
  • The peer review process
  • Data acquisition and laboratory tools; management, sharing and ownership of data and research tools
  • Research misconduct and policies for handling research misconduct
  • Authorship and publication
  • Science and engineering in society: the scientist and engineer as responsible members of society and ethical issues in research 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.  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, 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, or travel proposals.  The Policy also applies to NSF GRFP Fellows funded by Fellowship Offers effective with the 2010 Competition.

NIH ­­– This Policy applies to the following NIH 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. 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, 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.

The applicability criteria contained within this Policy may expand to cover other groups of researchers and sponsors in the future.

 

RCR

Responsible Conduct of Research

 

Procedures: 
5.1 Training Requirements by Funding Source
President's Undergraduate Research Awards (PURA) Program

All undergraduate students participating in Georgia Tech’s PURA Program must complete an online CITI RCR course (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 NSF or NIH

All undergraduate students paid in whole or in part from covered projects funded by NSF or NIH must complete both: (1) online RCR training and (2) in-person RCR training.

Undergraduate Online Requirement

The online training requirement involves successfully completing a CITI RCR course (http://www.rcr.gatech.edu/online-training). 

Undergraduate In-Person Requirement

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 projects funded by NSF or NIH must complete both: (1) online RCR training and (2) in-person RCR training.

Master’s Online Requirement

The online training requirement involves successfully completing a CITI RCR course (http://www.rcr.gatech.edu/online-training). 

Master’s In-Person Requirement
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 projects 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/). 

While the same form of online training (a CITI RCR course) is required for all applicable doctoral students, those who began their graduate program prior to Fall 2011 should check with OSP if they need to discuss other options for satisfying the in-person training requirement.

 

NSF-Funded or NIH-Funded Postdoctoral Researchers

All postdoctoral researchers paid in whole or in part from covered projects funded by NSF or NIH must complete both: (1) online RCR training and (2) in-person RCR training.

Postdoctoral Online Requirement

The online training requirement involves successfully completing a CITI RCR course (http://www.rcr.gatech.edu/online-training). 

Postdoctoral In-Person Requirement

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 CITI RCR course (http://www.rcr.gatech.edu/online-training). 

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

5.2 Deadline for Training Completion

Online Training Deadline The online training requirement described within this Policy, a CITI RCR course, must be successfully completed within ninety [90] days of first being appointed to a covered project. However, the online training requirement must be completed before an applicable person graduates or otherwise leaves the Institute even if that imposes a shorter deadline.
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 project or before the applicable person graduates or otherwise leaves the Institute even if that imposes a shorter deadline. A doctoral student funded by a covered project 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.

5.3 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 issue and ensure that their trainees adhere to that training plan.

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 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 (CITI) RCR training completions;
  • notifying trainees, staff, and/or PIs of any non-compliance of online (CITI) RCR training; 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;
  • 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 to ensure that the annual RCR certification to OSP can be submitted; and
  • retaining records of in-person training completed outside of OSP approved events or approved RCR courses.
Enforcement: 

Penalties for Non-Compliance

Students and Postdoctoral Researchers
Non‐compliance 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 project. Cases of student non-compliance may also be referred to the Dean of Students for additional disciplinary action.

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 by faculty or staff on a USDA NIFA project 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 project 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