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					                          University of South Alabama
                    FAQs for Responsible Conduct of Research
                                 January, 2010

                                       RCR Background

                                Proposals and Awards Timeline

                              USA’s RCR Institutional Training Plan

                                  Certification Requirements

                                     Completing Training

                                         Notifications

                                        Recordkeeping

                                       Help and Support


RCR Background

What is RCR?
       The acronym RCR stands for the Responsible Conduct of Research.

What does RCR include?
      RCR includes most professional activities that are part and parcel of a research career
      and that are under increasing regulatory scrutiny. As defined by federal agencies, RCR
      encompasses the following nine areas: research misconduct, human participants,
      research involving animals, data acquisition, management, sharing, and ownership,
      mentor/trainee responsibilities, publication practices and responsible authorship, peer
      review, collaborative science, and conflicts of interests.

Which sponsors require documentation of RCR training?
       NSF requires documentation for awards made for proposals submitted after 1/4/2010

       NIH for training related grants.
       See : http://grants.nih.gov/grants/guide/notice-files/NOT-OD-10-019.html

Why is the training required?
        To comply with the Congressional mandate under the America COMPETES Act (applies
        to NSF awards), NIH policies for training grants and career development awards, and to
        demonstrate USA’s commitment to providing the highest quality education for all
        students and scholars. Instruction in the Responsible Conduct of Research is
        fundamental in the preparation of our future scientists and engineers.


What is the America COMPETES Act?
        The America Creating Opportunities to Meaningfully Promote Excellence in Technology,
        Education, and Science Act of 2007 or America COMPETES Act was enacted to ensure
        our nation’s competitive position in the world through improvements in math and
        science education and to ensure a strong national commitment to research.
Why does RCR training apply to all projects if only NSF and NIH have RCR training requirements
for undergraduates, graduate students, and postdoctoral researchers?
       Because USA is committed to providing the highest quality education for all students and
       scholars and believes that instruction in the Responsible Conduct of Research is essential
       for encouraging and producing the best scientists and researchers for the future. See
       Institutional Policy on RCR Training for Students


Proposals and Awards Timeline

When does the NSF requirement go into effect?
      The requirement is effective for awards made against proposals submitted on or after
      January 4, 2010.

For NSF proposals, does the training plan need to be included with my grant proposal and
progress reports?
        There is no section in the standard NSF application for the PI to write or insert information
        about this training. By submitting the grant, the institution is certifying its intent to comply
        with this requirement. NOTE: A mentoring plan (Section 7008) is required if you request
        support for a postdoctoral fellow.

Do the RCR training requirements apply to subcontractors?
       Yes, certification by each subcontractor is required.


USA’s RCR Institutional Training Plan

How does USA provide certification to NSF of the Institutional Plan?
      USA’s Authorized Organizational Representative certifies that a plan is in place with each
      NSF proposal submission.

For NSF proposals, how will documentation be tracked, verifying that requirements have been
met ?
        The Office of Sponsored Programs certifies that USA has implemented an RCR training
        plan by signing the grant applications that are submitted to NSF. The PI will be
        responsible for informing new hires of the requirements. The Office of Research
        Compliance and Assurance (ORCA) will have to access to data available from the
        approved RCR training options and NSF funded research personnel. ORCA will
        periodically review the data for compliance and notify PIs of non-compliance. ORCA
        will make this data available upon request from NSF or individual faculty member.

Where can I find USA’s RCR Institutional Training Plan?
      It is online at the Research Compliance and Assurance website
      http://www.southalabama.edu/researchcompliance/responsible.html. This plan meets
      requirements of the NSP COMPETES Act Section 7009

Is RCR training required of all undergraduate/graduate students and postdoctoral fellows
receiving financial support, regardless of funding source?
        Yes

Are summer students required to complete RCR training?
       Yes, they must complete the appropriate training curriculum as defined in the RCR
       Training for Students policy document.

If I have taken RCR training at another institution does that satisfy the USA training requirements?
         The online CITI training certification is transferable for components that are shared
         among institutions. If additional training is required, which is dependent on level of
         education for students, other requirements specific to USA are not transferable.
Do undergraduates, graduate students and postdoctoral researchers paid by cost share
accounts have to complete the training requirements?
      Yes


Certification Requirements

Why are there different requirements for undergraduate, graduate student and postdoctoral
researchers?
       The USA RCR training plan is being tailored to meet the needs of the individuals and the
       career stage of those who participate in research. We believe a graduated, tiered
       approach is the best solution to meet these needs.

What is CITI?
       CITI stands for Collaborative Institutional Training Initiative and provides online training
       modules in RCR. https://www.citiprogram.org/Default.asp?

Is the RCR training requirement the same thing as NSF’s “Postdoctoral Mentoring Requirement”?
        No, the Postdoctoral Mentoring requirement is a separate initiative requiring the
        submission of a mentoring plan that is described in a supplemental document specific to
        each proposal submission. The plan is considered during the merit review process.
        Guidelines for addressing mentoring plans within grant applications are available on the
        Research Compliance and Assurance website
        http://www.southalabama.edu/researchcompliance/responsible.html

Does taking the CITI RCR online training program count for Human Subjects Training?
       No. Human Subject Protections require additional specific training for certification in the
       areas proscribed by federal regulatory requirements and institutional policies of the
       Institutional Review Boards.

Does the CITI online training plan count for animal care and use training?
       No. Animal Welfare requires additional specific training for certification in this area as
       required by federal regulations and institutional policies of the Institutional Animal Care
       and Use Committee.


Completing Training

How long do I have to take the training?
      Online training needs to be completed within 90 days of hire. Interactive training for
      graduate students or postdoctoral researchers is required during the first year of
      conducting research.

How long is the training good for?
      At this time, USA has not defined a training expiration period.

How do I access the online training?
      https://www.citiprogram.org/Default.asp??

Will I receive a certificate when my online training is complete?
         Yes, CITI provides a certificate upon completion. Additionally, the PI should expect to be
         contacted by the Office of Research Compliance to verify NSF funded students have
         completed the training.
Notifications

What happens if I don’t complete the training within the timeline?
      The responsible Principal Investigator will be notified by the Office of Research
      Compliance and Assurance and a corrective action plan will be required.

How will undergraduates/graduate students/postdocs know if the training requirement pertains
to them?
       The Principal Investigator/Supervisor is responsible for notification of training requirements.

What happens when someone does not comply?
      The Office of Research Compliance and Assurance will follow up individually with
      Principal Investigators and individuals to monitor compliance and will implement
      necessary corrective actions.


Recordkeeping

Who maintains the RCR training records?
     Documentation of the online CITI training should be maintained by the student and the
     PI. If the activity is sponsored research, then documentation should be maintained for a
     minimum of three years. The Office of Research Compliance and Assurance will be
     responsible for monitoring compliance with the institutional plan. For NSF sponsored
     research activities, the Office of Grants Administration requires RCR training
     documentation as part of the close-out process.


Help and Support

Who can I call with questions?
Office of Research Compliance and Assurance
   o    Dusty Layton, Director, dlayton@usouthal.edu
   o    Alison Henry, Assistant Director, ahenry@usouthal.edu




                                                       Adapted from Arizona State University

				
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