I. Scope

This policy and accompanying procedures apply to all grant research personnel who participate in research funded by the National Science Foundation (NSF) or the National Institutes of Health (NIH).

II. Introduction

The pursuit of truth motivates academic research at Earlham. Furthermore, Earlham’s Principles and Practices state, “Integrity calls us to be truthful, honest, and fair and to take responsibility for our actions and decisions.” It is with these values in mind that the community expects the highest standards of conduct from all faculty, staff, and students in research activities. The responsible and ethical conduct of research (RECR) is critical for excellence as well as public trust in science and engineering.

III. Definitions

Research Ethics – The ethics of planning, conduct, and reporting of research. The purpose of research includes protecting the interest of the public, the subjects of research, and the researchers themselves.[1]

Responsible and Ethical Conduct of Research – 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.[2]

Student Researcher – Undergraduate students participating in National Science Foundation (NSF) or National Institutes of Health (NIH) funded research, whether paid directly via the grant or not (e.g., receiving academic credit).

Grant Research Personnel – All principal investigators, senior personnel, post-doctoral researchers, graduate students, postbaccalaureate students, and undergraduate students who participate in research funded by the National Science Foundation (NSF) or the National Institutes of Health (NIH).

[1] Kalichman, M. (2010). Introduction: What is Research Ethics? Online Ethics Center for Engineering and Science. https://onlineethics.org/cases/resources-research-ethics-education/introduction-what-research-ethics

[2] National Institutes of Health. (2011, April 19) NOT-OD-10-019, Update on the Requirement for Instruction in the Responsible Conduct of Research

IV. Policy

The purpose of this policy is to set forth Earlham College’s requirements for researcher training on the responsible and ethical conduct of research for all National Science Foundation (NSF) and relevant National Institutes of Health (NIH) awards. This policy addresses current NSF and NIH requirements and will be amended, as needed, to address any additional agency requirements.

Faculty Principal Investigators (PIs) have the primary responsibility for complying with RECR training requirements on their awards and for training the undergraduate students involved in their research.

Section 7009 of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science (COMPETES) Act (42 USC 1862o–1), as amended, requires that each institution that applies for grants or support from the National Science Foundation (NSF) describe in its proposal a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel supported by the proposed research project. Such training must include mentor training and mentorship.[3]

National Institutes for Health (NIH) Notice NOT-OD-22-055 FY 2022 Updated Guidance: Requirement for Instruction in the Responsible Conduct of Research restates the NIH requirement for all trainees, fellows, participants, and scholars receiving support through any NIH training, career development, research education, or dissertation research grant to undertake RECR instruction at least once during each career stage, and at a frequency of no less than once every four years. In most circumstances, grant proposals to the NIH are required to include plans for instruction in responsible conduct of research.[4]

[3] National Science Foundation. (2024, January 22). Chapter IX: Recipient standards. Proposal & Award Policies and Procedures Guide (PAPPG).

[4] National Institutes of Health. (2022, February 17) NOT-OD-22-055, FY 2022 Updated Guidance: Requirement for Instruction in the Responsible Conduct of Research.

V. National Science Foundation (NSF) Procedure

For NSF-funded researchers, Earlham requires the completion of at least one of the following training options:

  • Completion of relevant online Collaborative Institutional Training Initiative (CITI) modules assigned based on project role.
  • Completion of an Earlham or another institution’s course or workshop on RECR can satisfy the training requirements or be used to supplement CITI training. Documentation of completion must be submitted to the Associate Director of Grants and Sponsored Research. The Associate Director of Grants and Sponsored Research will determine if the previous training satisfies Earlham’s requirements by comparing the training’s rigor against the CITI training modules.

Principal Investigators (PIs) are responsible for ensuring that all grant research personnel also complete the relevant CITI courses as appropriate for their roles. PI and senior personnel training include mandatory sections on mentoring.

Training should be completed within two months of a researcher’s commencement of work on an NSF-funded project. Where individuals are working on NSF projects for a short time, such as the summer, training should be completed during or before the first week of participation.

VI. National Institutes of Health (NIH) Procedure

CITI courses satisfy NSF requirements, but PIs of NIH grants need to coordinate the provision of or provide additional in-person training to grant research personnel. PIs on NIH funded grants should consult with the Associate Director of Grants and Sponsored Research on the creation of their project’s specific RECR training plan to ensure it meets NIH expectations prior to grant proposal submission.

While NIH has no specific curricular requirements, training plans for NIH should consider the subject matter recommendations spelled out in the NIH notice NOT-OD-22-055. These recommended topics include:

  1. personal, professional, and financial conflict of interest and conflict of commitment, in allocating time, effort, or other research resources
  2. policies regarding human subjects, live vertebrate animal subjects in research, and safe laboratory practices
  3. mentor/mentee responsibilities and relationships
  4. safe research environments (e.g., those that promote inclusion and are free of sexual, racial, ethnic, disability and other forms of discriminatory harassment)
  5. collaborative research, including collaborations with industry and investigators and institutions in other countries
  6. peer review, including the responsibility for maintaining confidentiality and security in peer review
  7. data acquisition and analysis; laboratory tools (e.g., tools for analyzing data and creating or working with digital images); recordkeeping practices, including methods such as electronic laboratory notebooks
  8. secure and ethical data use; data confidentiality, management, sharing, and ownership
  9. research misconduct and policies for handling misconduct
  10. responsible authorship and publication
  11. the scientist as a responsible member of society, contemporary ethical issues in biomedical research, and the environmental and societal impacts of scientific research

To satisfy the NIH requirement, RECR training plans must include discussion-based instruction with a substantive in-person interaction. RECR training plans NIH generally finds acceptable contain at least eight contact hours. Only short-term training and education programs supported by NIH (very specific grants lasting six or fewer months) may consider solely utilizing interactive video conferencing for RECR training.[5]

[5] National Institutes of Health. (2011, April 19) NOT-OD-10-019, Update on the Requirement for Instruction in the Responsible Conduct of Research

VII. Training Documentation

Upon completion of CITI coursework, each individual must submit their completion certificate to their PI. Principal Investigators (PIs) are responsible for submitting their team’s certificates to the Associate Director of Grants and Sponsored Research.

For NIH researchers, upon execution of an approved training plan, PIs will provide the Associate Director of Grants and Sponsored Research with the agreed upon certificates or course completion log for all grant research personnel. The NIH requires RECR training to be completed at least once during each career stage, and at least every four years.[6]

[6] National Institutes of Health. (2022, February 17) NOT-OD-22-055, FY 2022 Updated Guidance: Requirement for Instruction in the Responsible Conduct of Research.

VIII. Mentoring and Responsible and Ethical Conduct of Research

PIs and senior personnel are expected to discuss the RECR training and research ethics within their specific disciplines with their grant research personnel, but especially student researchers, prior to and after the completion of their training. While the RECR CITI training is designed to be broadly applicable across academic disciplines, accepted practices for the responsible conduct of research can and do vary among disciplines, which is why on-going face-to-face mentoring between PIs and their research is an essential secondary component of imparting discipline-specific values.

IX. Research Misconduct

In the event of suspected research misconduct, Earlham will investigate and apply sanctions in accordance with Earlham’s Research Misconduct Policy.

X. Resources

There are many resources for learning about and teaching research ethics. Here are a few of potential interest to the Earlham community:

Policy specifications

Last revision: 05/16/2024
Responsible office: Grants and Sponsored Research
Approved by: Provost
Approval date: 05/16/2024
Effective date: 05/16/2024
Related policies: Research Misconduct Policies and Procedures
Associated division(s):
Associated audience(s):

Associated container(s):
Policy home: https://earlham.edu/policy/responsible-and-ethical-conduct-of-research