Responsible Conduct in Research
Responsible Conduct in Research (RCR) is critical for College of the Holy Cross faculty and students. With or without federal mandate the institution would embrace the opportunity to ensure that students and faculty are responsibly and ethically conducting research.
THE NIH: According to the NIH’s notice “Update on the Requirement for Instruction in the Responsible Conduct in Research” Notice Number: NOT-OD-10-019, dated 11/24/09, upon award of any NIH Institutional Research Training Grants, Individual Fellowship Awards, Career Development Awards, Research Education Grants, Dissertation Research Grants or other grant programs with a training component that requires instruction in responsible conduct in research as noted in the Funding Opportunity Announcement, a formal training program which includes at least 8 hours of contact hours (face to face engagement) between faculty and trainees is required. This training program should be provided throughout the trainees’ scientific career and should occur as an undergraduate, graduate and post-doc student, as well as during Career Awards and other milestones in a scientist’s career.
The College of the Holy Cross provides resources to assist in this effort. The on-line training certificate program Collaborative Institutional Training Initiative (CITI) is available to faculty to assist in the development of a training program. The modules included in CITI can be used to guide and augment responsible conduct in research training in addition to face to face didactic interactions with students. Adequate training will include the following components:
a. Conflict of Interest: personal, professional, and financial
b. Policies regarding human subjects, live vertebrate animal subjects in research and safe laboratory practices
c. Mentor/mentee responsibilities and relationships
d. Collaborative research including collaborations with industry
e. Peer review
f. Data acquisition and laboratory tools; management, sharing and ownership
g. Research misconduct and polices for handling misconduct (please see the College of the Holy Cross Policy)
h. Responsible authorship and publication
i. The scientist as a responsible member or society, contemporary ethical issues in biomedical research, and the environment and societal impacts of scientific research
THE NSF: Pursuant to the 2007 America COMPETES Act, the National Science Foundation adopted a certification requirement effective January 4, 2010. The NSF Grant Proposal Guide states: “When submitting a proposal to NSF, the Authorized Organizational Representative is required to complete a certification that the institution has a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduates, graduate students, and postdoctoral researchers who will be supported by NSF to conduct research.” The plan must also include a system to verify that the training has occurred. The plan does not have to be submitted with proposals, but NSF could request it at any time – and NSF could audit compliance. Currently, institutions are free to develop their own plans, and at present there are no NSF-recommended models.
1. Faculty Principal Investigators (PIs) have the primary responsibility for training the students involved in their NSF-funded research. The Grants Routing Form requires a signature from any PI who submits an NSF proposal. This signature indicates that the PI agrees to participate in appropriate RCR training.
2. RCR (Responsible Conduct of Research) training will be required for all undergraduates receiving wages (or working as volunteers) or receiving academic credit for participating in NSF-funded research. Training must be completed within the semester or summer that the student begins work on the NSF-funded research.
3. RCR training will be documented at the project-level by the PI. Each PI will keep a list of students involved in NSF research and the date of RCR completion.
RCR training will include the following components:
a) Each student must successfully complete the appropriate Collaborative Institutional Training Initiative (CITI) module of RCR training. This requirement can be waived for students who have successfully completed an RCR workshop at another institution designed to satisfy NSF’s training requirement or other comparable training; the Director of Sponsored Research will specify what constitutes appropriate documentation in these cases.
b) PIs meet with the student/trainee throughout the training program and reinforce the RCR concepts presented in CITI.
CITI Instructions
To access the RCR training modules, please go to http://www.citiprogram.org to complete the registration and follow the instructions for RCR training. Please contact Sponsored Research if you encounter any problems.
1. On the right hand side there are three boxes; one with a place to login, a second to login through institutions, and a third to create an account. You want the THIRD option, click the "register" button.
2. This will bring you to the page where you will affiliate with Holy Cross. You will see a box that says "Select Your Organization Affiliation" Start to type College of the Holy Cross and it should populate in a drop down. Choose that and click "continue to step 2".
3. Next you will create your login and profile.
4. When you get to the "Curriculum" page you want to scroll to the question titled “Responsible Conduct of Research”. There are three check boxes in that question, you want to check whichever Learner Group applies to you (ie: Faculty, Student, etc.). Click "submit".
This will bring you to your course for completion.
*Please contact Sponsored Research if you have questions.