Guidance on Submitting NIH or NSF Proposals

Responsible Conduct of Research (RCR) Documentation

CSU is committed to providing training in ethics and the responsible conduct of research/scholarly inquiry. New federal statutes now mandate that some proposals document how we deliver such training. The CSU Institutional Conduct for Research Training Program policy describes our institutional approach to meeting federal guidelines. In general, NIH will address the adequacy of your RCR plan through its peer review process, so that grants receiving a fundable score will be retained by the Program Office until the RCR plan (or annual Progress Report) is judged to be meritorious. NSF, however, will likely audit universities after grant awards are made, checking that CSU is in compliance with our responsibility to train and track the training of personnel paid on NSF accounts.

Click here to view representative examples of excerpts from grants

National Science Foundation (NSF)

There are two sections of the America Competes Act that describe new RCR training requirements.

Section 7008: Mentoring Plans for all postdoctoral fellows. (42 USC 1862o)

Each proposal that contains postdoctoral researchers must include, as a supplementary document, a description of the mentoring activities that will be provided for such individuals. The mentoring plan must not exceed one page.
Mentoring activities may include career counseling, training in preparing grant applications, guidance on ways to improve teaching skills, and training in research ethics.
In addition, all progress reports for research grants that include funding to support postdoctoral researchers must include a description of the mentoring activities provided to such researchers.
Samples of plans may be found here (hyperlink).

Section 7009: RCR Instruction (42 USC 1862o-1)

CSU PIs are currently in compliance with Section 7008 by virtue of the establishment of the CSU institutional RCR training program. According to the CSU policy, PIs must require RCR instruction for all undergraduates, graduates and postdoctoral fellows who are paid salary on the NSF grants. No additional actions are needed at the time of grant submission; nor are additional progress report actions needed.

FAQs about NSF RCR requirements

National Institutes of Health (NIH)

The National Institutes of Health (NIH) has established policy that requires formal, face-to-face RCR instruction to certain types of trainees. (NOT-OD-10-019) The CSU institutional policy has extended that requirement to ALL NIH-funded trainees, regardless of the training mechanism.

New institutional applications (T15, T32, T34, T90/R90, TL1, K12, or K30):

Must include a plan for instruction in responsible conduct of research. The plan must address the five instructional components, and the plan must describe how participation in instruction in responsible conduct of research will be monitored. The following may be used

Format: Trainees will receive face-to-face instruction in a CSU Provost-approved RCR course
Subject matter: Trainees will receive instruction in 1)Ethics and social responsibility in research; 2) Conflict of interest; 3) The use of animal/human subjects and safe laboratory practices; 4) Mentor/mentee responsibilities; 5) Collaborative research; 6) Data acquisition, management, sharing, and ownership; 7) Research misconduct; 8) Responsible authorship, publication and peer review; 9) Financial management and responsibilities
Faculty participation: Formal courses are taught by tenure-track or tenured faculty who do research and teaching within various departments at CSU. Faculty contributing to RCR instruction will have discipline-specific expertise in humanities, social sciences, physical sciences or life sciences, as appropriate. One-on-one faculty mentoring will also be provided. Enhanced mentoring will be promoted through "training the trainer workshops" and access to the CSU online RCR Resource Center.
Duration of instruction: Formal instruction in an approved RCR course will entail 16-45 contact hours, over one semester. Mentoring will be ongoing throughout the career of the trainee.
Frequency of instruction: Formal training will occur at least once at each training stage, and/or every 4 years of training.

Must include a plan for monitoring.

The Director of the Research Integrity & Compliance Review Office RICRO) shall monitor RCR instruction. All trainees will be required to take an institutional RCR online training course and a face-to-face, CSU-approved, formal RCR course, and their participation will be tracked and verified by RICRO.

For renewal (Type 2) applications:

Must, in addition, describe changes in formal instruction over the past project period and plans for the future that address and weaknesses in the current instruction in RCR. All training faculty who served as course directors, speakers, lecturers, and/or discussion leaders during the past project period must be named in the application.

Institutional Reporting:

Continuation (Type 5) applications must describe the nature of the instruction in responsible conduct of research and the extent of trainee and faculty participation as required in the PHS 2590. This report must include a description of any enhancements and/or modifications to the five instructional components from the plan described in the awarded application. Specific training faculty members who were contributors to formal instruction in responsible conduct of research during the last budget period must be named.

New Individual Applications

New (Type 1) applications must include a section on instruction in responsible conduct of research, appropriate to the career stage of the applicant (instruction for applicants in the early stages of their careers; participation as course directors, lecturers, or discussion leaders for applicants in middle or senior stages of their careers), as part of the Research Training Plan or Candidate Information and Career Development Plan. This section will document prior participation or instruction in responsible conduct of research during the applicant's current career stage (including the date instruction was last completed) and propose plans to either receive instruction in responsible conduct of research or participate as a course lecturer, etc., depending on the applicant's career stage. Such plans must address the five instructional components outlined above. The plan may include career stage-appropriate, individualized instruction or independent scholarly activities that will enhance the applicant's understanding of ethical issues related to their specific research activities and the societal impact of that research. The role of the sponsor/mentor in instruction in responsible conduct of research must be described.

Renewal:

Where applicable, renewal (Type 2) applications must describe instruction in responsible conduct of research activities undertaken during the past project period as well as future plans in order to meet the frequency requirement as outlined above in Instructional Components.

Individual Reporting:

Continuation (Type 5) applications must report specifically on instruction for the fellow in responsible conduct of research. This report must include subject matter covered, format, frequency and duration of instruction, or indicate when during a previous or future budget period instruction in responsible conduct of research did or will take place. The report should discuss both formal and/or informal instruction in responsible conduct of research and should note the extent to which the sponsor or senior fellow participated in these activities.