RCR FREQUENTLY ASKED QUESTIONS

Q: What is Responsible Conduct of Research (RCR)?​
Q: What are the Responsible Conduct of Research (RCR) training requirements for specific funding agencies?​
Q: Who needs to take the Responsible Conduct of Research (RCR) training?​
Q: When must the Responsible Conduct of Research (RCR) training be completed?​
Q: When did the Responsible Conduct of Research (RCR) training policy go into effect?​
Q: Are all researchers required to receive Responsible Conduct of Research (RCR) training at Brown?​
Q: Where can Responsible Conduct of Research (RCR) training be obtained?​
Q: Is Responsible Conduct of Research (RCR) training different from the Human Subjects Collaborative Institutional Training Initiative (CITI) training that is required?​
Q: Who is responsible to ensure the Responsible Conduct of Research (RCR) training has been completed, including retaining completion records?
Q: Must a Responsible Conduct of Research (RCR) training component be submitted along with the grant application?
Q: Does the Responsible Conduct of Research (RCR) requirement flow down to any sub-awardee identified on the project?
Q: Does a sub-award to an international organization have to include the Responsible Conduct of Research (RCR) requirement?
Q: Does the Responsible Conduct of Research (RCR) training plan have to be in place before any award is made, or at the time of proposal submission?
Q: I have taken a course involving Responsible Conduct of Research (RCR) topics at another institution. Can I apply this course toward the Brown RCR requirements?
Q: What are the RCR responsibilities of the PI of NIH institutional training grants (T32 awards)?

New NSF Regulations (effective July 31, 2023)
Q: When do the new NSF regulations take effect?
Q: How are the new NSF regulations different from what I have been doing?
Q: Who is affected by the new NSF regulations?
Q: How can I meet the requirements of the new NSF regulation?
Q: I already completed RCR training for my NIH grant. Do I have to re-train to meet the new NSF requirement?

Q: What is Responsible Conduct of Research (RCR)​?

A: Responsible Conduct of Research (RCR) is defined 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. Projects funded by the National Institutes of Health (NIH), National Science Foundation (NSF), and National Institute of Food and Agriculture (NIFA) have specific requirements regarding training in RCR.

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Q: What are the Responsible Conduct of Research (RCR) training requirements for specific funding agencies?​

A:

Federal Agency

Minimal Requirement for RCR

NIH*

At least 8 hours of face-to-face training/interaction in a course that involves faculty instructors

NSF

CITI online RCR or face-to-face training

NIFA

CITI online RCR or face-to-face training

*For NIH, the RCR requirements apply to all NIH Institutional Research Training Grants, Individual Fellowship Awards, Career Development Awards (Institutional and Individual), Research Education Grants, and Dissertation Research Grants. The programs are listed as: 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.

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Q: Who needs to take the Responsible Conduct of Research (RCR) training?​

A:

Federal Agency

Who Must Complete the Training

NIH*

Trainees, Fellows, Postdoctoral Scholars, Graduate Students, Undergraduate Students on the specified award types

NSF

Undergraduate Students, Graduate Students and Postdoctoral Students supported to conduct research

NIFA

Program Directors, Faculty, Undergraduate Students, Postdoctoral Scholars, any staff participating in the project

*For NIH, the RCR requirements apply to all NIH Institutional Research Training Grants, Individual Fellowship Awards, Career Development Awards (Institutional and Individual), Research Education Grants, and Dissertation Research Grants. The programs are listed as: 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.

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Q: When must the Responsible Conduct of Research (RCR) training be completed?​

A: The National Institutes of Health (NIH) highly encourages that initial instruction during predoctoral training occur as early as possible in graduate school. The completion of training should be consistent with the responsible conduct of research plan included in the NIH grant application.

The National Science Foundation (NSF) does not specify when the training must be completed, but a plan must be in place at the time of proposal submission.

The National Institute of Food and Agriculture (NIFA) requires the training be completed before participation in or payment from the project.

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Q: When did the Responsible Conduct of Research (RCR) training policy go into effect?​

A: The National Institutes of Health (NIH) RCR training requirement became effective for all new and renewal applications submitted on or after January 25, 2010, and for all continuation (Type 5) applications with deadlines on or after January 1, 2011. 

The National Science Foundation (NSF) Responsible Conduct of Research (RCR) training requirement became effective for new proposals submitted or due on or after January 4, 2010

National Institute of Food and Agriculture's (NIFA) implemented revised Research Terms and Conditions (RTCs) effective June 30, 2017. These RTCs include an updated Responsible Conduct of Research (RCR) training requirement for NIFA grant recipients.

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Q: Are all researchers required to receive Responsible Conduct of Research (RCR) training at Brown?​

A: Brown is highly committed to maintaining a research environment that promotes adherence to the highest ethical standards for all sponsored and non-sponsored research. At this point in time, only research projects with a specific Responsible Conduct of Research (RCR)  requirement, as outlined in the “Who needs to take the Responsible Conduct of Research (RCR) training?” question, will be monitored to assure compliance with the funding agencies’ respective requirements.

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Q: Where can Responsible Conduct of Research (RCR) training be obtained?​

A: 

Options

Availability

Federal Agency Requirements

Brown RCR Programs

Preference given to students, trainees and faculty on qualifying awards

All

CITI RCR online course

Everyone with a Brown University affiliation

Only meets NSF And NIFA requirements, does not meet standard of face-face training for NIH

Customized Department Courses*

Every Department

Can be customized to meet all requirements

*Any department wishing to pursue this option must contact the Office of Research Integrity and work collaboratively to design a program of instruction that fulfills regulatory requirements.

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Q: Is Responsible Conduct of Research (RCR) training different from the Human Subjects Collaborative Institutional Training Initiative (CITI) training that is required?​

A: Yes, please note that Responsible Conduct of Research (RCR) training is separate from human subjects research training required for Institutional Review Board (IRB) submissions.

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Q: Who is responsible for ensuring the Responsible Conduct of Research (RCR) training has been completed, including retaining completion records?

A: Brown’s Office of Research Integrity (ORI) notifies investigators of any RCR training requirements associated with their awards. PIs are expected to ensure that any individual who meets RCR training requirement criteria completes an appropriate RCR training program. 

Students, postdocs, and junior faculty who must complete RCR training are expected to take personal responsibility to complete a qualifying course (and additional courses, as required) throughout their research career at Brown.

ORI centrally tracks successful completion of Brown CITI RCR course. However, individuals who complete the CITI RCR course are expected to maintain their CITI training completion certificates for the duration of their tenure at Brown, and when they leave Brown for another institution.

Starting in 2020, ORI will maintain records of training completion for anyone who has completed a Brown RCR Program. If an individual completes an approved, customized departmental course, it is the responsibility of the department to retain completion records and to send to ORI a list of course completers.

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Q: Must a Responsible Conduct of Research (RCR) training component be submitted along with the grant application?

A: The National Institutes of Health (NIH) requires that all institutional training grants, individual fellowships, career development awards, research education grants, and dissertation research grants include a description of activities related to instruction on RCR with each application. PIs are encouraged to use Brown’s templates as a starting point for their plans of RCR instruction.

Training plans are not required to be included in proposals submitted to National Science Foundation (NSF) or National Institute of Food and Agriculture (NIFA); however, a training plan must be in place at the time of proposal submission and must be made available upon request.

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Q: Does the Responsible Conduct of Research (RCR) requirement flow down to any sub-awardee identified on the project?

A: Yes. At the time of proposal submission, the Authorized Organizational Representative of the proposing institution is responsible for certifying that its 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 to conduct research. The RCR training requirement does flow down to all sub-awardees, at any tier. The proposing institution must therefore ensure that these RCR requirements are appropriately addressed in the sub-award instrument.

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Q: Does a sub-award to an international organization have to include the Responsible Conduct of Research (RCR) requirement?

A: The RCR requirement flows down to all sub-awardees, including international organizations. If there are undergraduates, graduates, and postdoctoral researchers supported on the award to conduct research, they must be trained in the responsible conduct of research.

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Q: Does the Responsible Conduct of Research (RCR) training plan have to be in place before any award is made, or at the time of proposal submission?

A: The RCR training plan must be in place at the time of proposal submission for all funding agencies. National Institutes of Health (NIH) requires that the training plan be discussed in the proposal.

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Q: I have taken a course involving Responsible Conduct of Research (RCR) topics at another institution. Can I apply this course toward the Brown RCR requirements?

A: No. The NIH and NSF require completion of RCR requirements during the period of grant support. In exceptional circumstances, NIH may permit completion of the RCR course outside of the period of NIH support. Such cases will be reviewed by ORI on a case-by-case basis.

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Q: What are the RCR responsibilities of the PI of NIH institutional training grants (T32 awards)?

A: PIs of NIH institutional training grants are responsible for ensuring that T32 supported trainees complete RCR training. This includes notifying trainees of the RCR requirement, requiring completion of the RCR requirements as a condition of the training grant appointment, and reporting on RCR activity to the NIH.

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New NSF Regulations

Q: When do the new NSF regulations take effect?

The new NSF regulations apply to grants submitted for funding to NSF on or after July 31, 2023. If awarded, all individuals participating in the NSF funded research will be required to complete RCR training. This includes PIs, Co-PIs, senior research personnel, postdocs, graduate and undergraduate students. 

Q: How are the new NSF regulations different from what I have been doing?

The new NSF regulations expand the RCR requirement to include PIs and senior personnel. PIs and senior personnel will need to complete RCR training that includes information on mentoring. There is no change to the requirement already in place for trainee researchers (undergraduate and graduate students) and post docs funded by NSF awards.

Q: Who is affected by the new NSF regulations?

The new NSF regulations expand the RCR requirement to include PIs and senior personnel on NSF awards resulting from proposals submitted on or after July 31, 2023. PIs and senior personnel will need to complete RCR training that includes information on mentoring. The CITI RCR module meets the NSF requirement. Please contact the BEARCORE RCR coordinators if you would like to explore other ways to meet the requirement.

Q: How can I meet the requirements of the new NSF regulation?

Researchers can complete the CITI program online or any of Brown’s existing RCR programs at the start of the NSF award. Principal Investigators should be attentive to additional email communications from the RCR coordinators for updates to the NSF requirements and ensure that the information is disseminated to their NSF-funded trainees. Training requirements continue to evolve; we will update the research community as needed. 

Q: I already completed RCR training for my NIH grant. Do I have to re-train to meet the new NSF requirement? 

If you have completed Brown RCR training within the past 4 years, this is sufficient. The NIH RCR programming meets the NSF requirement.

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