Office of Research Development Eastern Michigan University Standard Operating Procedure: Meeting National Science Foundation Responsible Conduct of Research Requirements Introduction Eastern Michigan University prides itself on faculty-­‐student interaction as it relates to all aspects of learning. Pertaining to research, faculty members work closely with both undergraduate and graduate students. Faculty members at EMU see research as part of the education process, not a separate activity. In 2000, after the Office of Research Integrity had rescinded its requirement for institutions to require responsible conduct of research (RCR) training, the University’s Academic Integrity Committee made the recommendation that the institution move forward in developing nine online modules that could be used: 1) to satisfy the NIH training requirement for training related to the protection and use of human subjects for Principal Investigators who were submitting proposals to NIH; and 2) as a resource for faculty teaching research courses. Three modules each were completed each year over the next three years, with full implementation in the 2002-­‐2003 academic year. The EMU RCR modules have been in use for almost a decade, and while serving their intended purpose, the AIC has articulated the need to update the resources available at EMU. This is being accomplished during the 2009-­‐2010 academic year by becoming subscribing members in the Collaborative Institutional Training Initiative (CITI). Addressing the National Science Foundation RCR Education Requirement In response to the Section 7009 of the America COMPETES Act, the National Science Foundation (NSF) will require all institutions applying for funding from NSF for science and engineering research, or education provide appropriate training and oversight in the responsible and ethical conduct of research to all participating undergraduate students, graduate students, and postdoctoral researchers. Specifically, institutions must: 1. Have a plan in place to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate student, graduate student, and postdoctoral researchers who are supported by NSF to conduct research. 2. Have designated one or more persons to oversee compliance with the RCR training requirement. 3. Verify that undergraduate student, graduate student, and postdoctoral researchers supported by NSF to conduct research have received training in the responsible and ethical conduct of research. While training plans are not required to be included in proposals submitted to NSF, institutions are advised that they are subject to review, upon request, and thus the Principal Investigator (PI)_ must develop a plan before submitting the proposal. Beginning with all proposals submitted on or after January 4, 2010, and as noted in Chapter II.C.1e of the NSF Grant Proposal Guide (NSF 10-­‐1), institutional certification to this effect is required for each proposal by the Authorized Organizational Representative (AOR). At EMU, the AOR is the Director of the Office of Research Development. NSF’s preparation of implementing Section 7009 of the America COMPETES Act funded a workshop, “Ethics Education: What’s Been Learned? What Should be Done?” hosted by the National Academies of Science & Engineering. In this workshop, participants concluded that: • Non-­‐instructor lead on-­‐line only training is less effective than that which is instructor lead; • Ethics training should be integrated into scientific and engineering research; • Multiple approaches are needed; • Time available for training must be considered; • Content can vary by disciplinary areas and career age (undergrad versus post doc); and • PIs should be positively involved. Therefore, the PI and Co-­‐PIs are asked to engage in an ongoing dialogue, and lead other instructional activities about the responsible and ethical conduct of research throughout the NSF funded research experience. The RCR Training Plan will require a short description of those ongoing activities. Operating Procedure Eastern Michigan University’s institutional program for providing Responsible Conduct of Research education for all undergraduate student, graduate student, and postdoctoral researchers supported by NSF funding includes: 1) The completion of a PI-­‐developed plan prior to submitting the proposal to NSF; 2) A process to verify that student and postdoctoral researchers have completed fundamental online courses identified in the plan; and 3) A certification statement made by the PI that all activities described in the plan were completed in a timely manner. Prior to submitting a proposal to National Science Foundation, the Principal Investigator will complete the RCR Training Plan form, (please see attached) that: 1) identifies fundamental online instructional modules student and postdoctoral researchers will be required to complete soon after being assigned to an NSF supported project; and 2) provides a description of additional educational activities as designed and described by the PI in the plan. Principal Investigators will be required under the America Competes Act by the National Science Foundation to develop an RCR plan prior to submitting the proposal to NSF. 1. Completion of Online Instruction: Eastern Michigan University will make basic online modules available through the Collaborative Institutional Training Initiative (CITI) in order to provide a minimum level of instruction. EMU requires all student, and postdoctoral researchers funded by NSF to complete the following modules: a) research misconduct, b) data acquisition and management, c) responsible authorship and publication practices, and d) peer review process. In addition, the PI may require students to complete some of all of the following elective modules: a) mentor and trainee responsibilities, b) conflicts of interest, and c) collaborative research. In addition, student, and postdoctoral researchers whose research directly involves human subjects or animals will be required to take either the course providing in-­‐depth instruction in protection and use of human subjects, or care and use of animals, as deemed appropriate to the research and by its Principal Investigator. 2. PI lead educational experiences. The Principal Investigator should design additional educational experiences so that the PI can certify that each student and post doctoral researcher assigned to the project demonstrate the following within the first three months: a) familiarity with the codes of ethics, or other professional codes, associated with the relevant professional society or societies; b) familiarity with EMU policies and procedures pertaining to research regulatory compliance; c) familiarity with any additional standards that apply to department(s) and lab(s) in which the research is conducted; and d) the student or post doc has demonstrated the ability to apply the standards discussed in the online instruction, and items a-­‐c above to analyze non-­‐trivial case studies. This last requirement is not intended to be onerous, and could be satisfied through one-­‐on-­‐one discussions between the student and the Principal Investigator. As an alternative student researchers may satisfy the NSF requirement for responsible conduct in research instruction by taking a course. In the event that the department where the research is taking place has an Academic Integrity Committee-­‐approved course in ethics, that course may be used in place of items one and two above providing that the student takes the course at the earliest opportunity after beginning the project, or has already completed the course. The Principal Investigator will be responsible for reviewing the students transcript and certifying that the student has completed the course. Institutional Oversight
The Office of Research Development will collect RCR Training Plans at the time of submission, keeping them on file as required by NSF. Upon award, ORD will include a copy of the RCR Training Plan in the award packet that is distributed to both the PI and Grants and Contacts Accounting. Student and postdoctoral research assistants will be required to complete the online courses and additional educational experiences within the first three months of their joining the funded project. Upon completion the PI will sign a certification statement that must be submitted to the Manager of Grants and Contracts Accounting. Pay for students beyond the three-­‐month period may be withheld until the activities are completed, and certification statements made. We suggest that the PI collect the certificates of completion from student and postdoctoral researchers, attaching a copy of the plan, and then forwarding them to Grants and Contracts Accounting. Upon closeout of the grant award, Grants Accounting will forward the RCR Training Plan back to the PI, asking that he or she sign a second statement certifying that ongoing RCR training activities as described in the plan were completed. Office of Research Development Eastern Michigan University Responsible Conduct of Research Training Plan for all undergraduate, graduate, and postdoctoral researchers supported with NSF funding Proposal Title: Submission Date: Date: On January 4, 2010 the National Science Foundation implemented a requirement that all undergraduate students, graduate students, and postdoctoral researchers supported with NSF funding receive training in the responsible and ethical conduct of research. Instructions: Please complete this form, returning it to the Office of Research Development prior to submitting your NSF Proposal. Minimum Level of Online Instruction 1. All student and postdoctoral researchers assigned to NSF grants will be required to complete the following Responsible Conduct of Research modules: • Research misconduct • Data acquisition and management • Responsible authorship and publication practices, • Peer review process. 2. Complete any additional elective RCR modules as identified by the PI: Mentor and trainee responsibilities Conflicts of interest Collaborative research 3. Complete either of the following as determined appropriate to the research by its PI: Protection and Use of Human Subjects; or Care and Use of Animals Description of Additional Education Activities Please provide a description of activities designed so that you can certify that each student and post doctoral researcher assigned to the project demonstrates the following within the first three months of joining the funded project: a) familiarity with the codes of ethics, or other professional codes, associated with the relevant professional society or societies; b) familiarity with EMU policies and procedures pertaining to research regulatory compliance; c) familiarity with any additional standards that apply to department(s) and lab(s) in which the research is conducted; and d) ability to apply the standards discussed in the online instruction, and a-­‐c above to analyze non-­‐trivial case studies Form fill field here for plan completion.
If the student researcher(s) will satisfy the RCR requirement through taking an Academic Integrity Committee-­‐approved ethics course, indicate the course that will be used in the terms in which they are offered. Course: Terms in which the course is offered: Certification Statement (signed at the time of proposal submission) As the Principal Investigator of the above referenced grant, I hereby certify that I understand that it is my responsibility to see that the plan provided herein is implemented, and to ensure that undergraduate students, graduate students, and postdoctoral researchers supported with NSF funding receive training in the responsible and ethical conduct of research. Signature Date Certification Statement (signed three-­‐months after the project start-­‐date) As the PI of the above referenced grant, I hereby certify that the undergraduate student, graduate student, and postdoctoral researchers supported with NSF funding have received instruction in the ethical and responsible conduct of research as described in this plan, including: 1. Completion of all required online instruction; and 2. Additional educational activities so that the student or postdoctoral researcher and can demonstrate that: a) he or she is familiar with the codes of ethics, or other professional codes, associated with the relevant professional society or societies; b) he or she is familiar with EMU policies and procedures pertaining to research regulatory compliance; c) he or she is familiarity with any additional standards that apply to department(s) and lab(s) in which the research is conducted; and d) he or she has demonstrated the ability to apply the standards discussed in the online instruction, and a-­‐c above to analyze non-­‐trivial case studies. Signature Date