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RCR Policy

Responsible Conduct of Research Policy

The University of Houston is committed to supporting responsible and ethical conduct of research and scholarship among its faculty, staff and students. Responsible conduct of research should foster a climate of intellectual honesty and a commitment to ethical responsibilities by academia. All members of the University community share responsibility for developing and maintaining standards to assure ethical conduct of research and detection of abuse of these standards. (See Ethical Conduct in Academic Research and Scholarship for the University’s policy on handling misconduct in research and scholarship.)

The University of Houston continually strives to maintain a research environment that promotes attention to the highest ethical standards for all sponsored and non-sponsored research. It is expected, therefore, that all researchers participate in ongoing education in all core areas that comprise a comprehensive responsible conduct of research curriculum. These core areas include:

  • Conflict of interest
  • Human subjects, animal, and safe laboratory practices
  • Mentor/mentee responsibilities and relationships
  • Collaborative research
  • Peer review
  • Data acquisition, management, sharing and ownership
  • Research misconduct
  • Responsible authorship and publication
  • Scientist as a responsible member of society

Recipients of awards from the National Science Foundation (NSF), the USDA National Institute of Food and Agriculture (NIFA), and the National Institutes of Health (NIH) are required to comply with specific requirements to ensure appropriate training in the responsible conduct of research. Researchers applying for, and receiving, support from NSF, NIFA and the NIH will need to be familiar with these respective regulations, as well as provide documentation of appropriate training as required under the terms of the award. Regardless of funding, however, these core ethical values are expected to be upheld in all research conducted at the University and research team education in all applicable areas is highly encouraged.

National Science Foundation (NSF) Requirements for Responsible Conduct of Research (RCR)

The National Science Foundation (NSF) has established a training requirement in the Responsible Conduct of Research (RCR) for students and postdoctoral fellows (postdocs) supported by NSF projects.  The requirement applies to all undergraduates, graduate students, and postdoc researchers who are supported by NSF projects submitted (and subsequently awarded) after January 4, 2010; including competitive renewals (see the NSF Guide for more on the requirement). The new regulations implement provisions of the America COMPETES Act, which requires grantees to provide training and oversight in the responsible and ethical conduct of research for undergraduate and graduate students and postdocs.  However, it is strongly recommended that faculty, including principal investigators, also review and become familiar with the content of the issues concerning ethical research.

At the time an NSF proposal is submitted, the Grants and Contracts office  must certify that the University of Houston has a plan to provide appropriate training and oversight for students (undergraduate and graduate) and postdoctoral fellows, who will be supported by NSF, to conduct research. Plans are not to be submitted with proposals but they are subject to review on request by NSF.

NSF has not specified the content and mode of delivery of the training in the responsible conduct of research, but they have suggested that seminars, web-based programs, workshops and mentoring are some of the acceptable methods of delivery. The University of Houston participates in the Collaborative Institutional Training Initiative (CITI), a subscription service providing research ethics training to members of the research community. Therefore, all students and postdocs supported by an NSF project are required to complete, at a minimum, the CITI online training in the Responsible Conduct for Research.

NSF expects that the RCR training be delivered during the first year of an award; however we recommend that it be taken within 180 days of an individual starting work on the project, to ensure integrity is maintained throughout.

Principal Investigators are responsible for ensuring completion of the RCR education requirements by all postdocs, graduate students, and undergraduates who are supported by NSF projects, including subawards, submitted and subsequently awarded. The Division of Research Office of Research Policies, Compliance and Committees will, on a periodic basis, monitor completion of CITI training. The PI will be notified of any individuals who have not satisfied this training requirement. 

Noncompliance:

Failure to comply with this policy within specified time frames shall constitute grounds for disciplinary action. Disciplinary action is based upon a reasonable investigation of the noncompliance and is consistent with the severity of the violation. A range of examples includes, but is not limited to, additional training/monitoring for minor violations up to limits being placed on the use of NSF-awarded funds for the project supporting these personnel, and/or loss of privilege to apply for new grant funding until the required training has been brought into compliance.

U.S. Department of Agriculture (USDA) National Institute of Food and Agriculture (NIFA) Requirements for Responsible Conduct of Research (RCR)

USDA NIFA considers education in RCR critical for excellence, as well as public trust, in science and engineering. The agency requires that program directors, faculty, undergraduate students, postdoctoral researchers, and any staff participating in the awarded research project receive appropriate training and oversight in the responsible and ethical conduct of research; documentation of such training must be maintained and provided to NIFA upon request.

NIFA specifies general requirements for RCR training and indicates that grantees consider CITI training specifically. Therefore, all required research personnel supported by NIFA are required to complete, at a minimum, the CITI online training in the Responsible Conduct for Research.

It is the responsibility of the PI to ensure that appropriate training has been completed by all individuals associated with the funded work. The Division of Research Office of Research Policies, Compliance and Committees will, on a periodic basis, monitor completion of CITI training. The PI will be notified of any individuals who have not satisfied this training requirement. 

Noncompliance:

Failure to comply with this policy within specified time frames shall constitute grounds for disciplinary action. Disciplinary action is based upon a reasonable investigation of the noncompliance and is consistent with the severity of the violation. A range of examples includes, but is not limited to, additional training/monitoring for minor violations up to limits being placed on the use of NSF-awarded funds for the project supporting these personnel, and/or loss of privilege to apply for new grant funding until the required training has been brought into compliance

National Institutes of Health (NIH) requirements for Responsible Conduct of Research (RCR)

NIH requires that all Institutional Research Training Grants, Individual Fellowship Awards, Career Development Awards (institutional and individual), Research Education Grants, Dissertation Research Grants or other grant programs with a training component include a plan for how the PI will carry out instruction in responsible conduct of research. Specifically, this applies to the following types of grants:  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, U2R. Although this plan does not affect overall impact scores, applications will be considered incomplete and will not be reviewed until an acceptable plan of instruction is submitted.

All trainees, fellows, participants, and scholars receiving support are required to complete RCR training. Instruction should include face-to-face discussions (online can be a component, but is not sufficient). Substantial face-to-face discussion, combination of didactic and small-group discussions (e.g. case studies), and participation of research training faculty members in instruction are highly encouraged. A minimum of 8 contact hours are considered to be substantive (semester-long-series of seminars/programs ideal). Instructions must be undertaken at least once during each career stage (undergraduate, post-baccalaureate, predoctoral, postdoctoral, faculty), but no less than once every four years.

NIH has not mandated specific subject requirements, but most acceptable plans have included conflict of interest; human subjects, animal, and safe laboratory practices; mentor/mentee responsibilities and relationships; collaborate research; peer review; data acquisition and lab tools; data management, sharing and ownership; research misconduct; responsible authorship and publication; and scientist as a responsible member of society.  (See NIH’s Update on the Requirement for Instruction in the Responsible Conduct of Research to learn more about NIH’s requirements.)

The Division of Research has created a “Recommended Plan for Responsible Conduct of Research by Career Stage” matrix to assist researchers in satisfying these educational requirements. Note that the matrix categories are suggestions and are not meant to limit any trainee to only certain types of training.

It is the responsibility of the PI to ensure that appropriate training has been completed by all individuals associated with the funded work. The Division of Research Office of Research Policies, Compliance and Committees will, on an annual basis, monitor compliance with the RCR plan outlined in the funded grant. In cases where UH is a subrecipient, general NIH RCR requirements must be met.

Noncompliance:

Failure to comply with this policy within specified time frames shall constitute grounds for disciplinary action. Disciplinary action is based upon a reasonable investigation of the noncompliance and is consistent with the severity of the violation. A range of examples includes, but is not limited to, additional training/monitoring for minor violations up to limits being placed on the use of NIH-awarded funds for the project supporting these personnel, and/or loss of privilege to apply for new grant funding until the required training has been brought into compliance.