NSF-required training for faculty and senior personnel
The CHIPS and Science Act of 2022 amended the America COMPETES Act (42 USC 18620-1 for the National Science Foundation’s (NSF) required training in the responsible and ethical conduct of research (RECR). In addition to undergraduate students, graduate students, and post-doctoral fellows, faculty and senior personnel must also complete RECR training. There are also changes to required content in RECR training, including mentoring and mentorship, research security and mitigation of research security risks, and federal export control.
The Office of the Vice President for Research has created a RECR CITI training course for NSF-funded faculty and senior personnel. Faculty and senior personnel must complete the course within 30 days of notification of funding from the NSF. The RECR course is limited to NSF faculty and senior personnel.
How Is This Different From RCR Training Requirements?
Responsible Conduct of Research (RCR) training is the NIH equivalent to the NSF’s RECR. Under the federal regulations governing RCR, undergraduates, graduate students, post-doctoral fellows and junior faculty and trainees on K- or T-awards must complete training on a specified list of topics (See the UI RCR Plan). Historically, trainees did not include faculty, key personnel (NIH) or senior personnel (NSF). Additionally, until the passage of the CHIPS and Science Act of 2022, the NSF did not have specific topics that had to be covered in RECR, they only required that training be conducted. The University of Iowa, like most academic institutions, use the NIH’s requirements for required training to establish our RCR Training Plan, which includes both online learning and in-person instruction. There are also requirements for when training must occur (i.e., at each trainee level, and frequency for refresher training at each trainee level).
With the new requirements from the NSF for RECR, faculty and senior personnel must complete training in mentoring training and mentorship, research security risks and mitigation of those risks, and federal export controls. There are no specified requirements for in-person training or frequency for re-taking training. Under the University of Iowa’s RCR Plan, NSF faculty and senior personnel will enroll in and take the specially designed RECR CITI course once.
Who Must Take RECR Training?
Principal Investigators (PI), co-Principal Investigators (co-PI) and senior personnel must complete RECR training. NSF defines senior personnel as anyone responsible for the scientific or technical direction of the project along with other key personnel involved such as faculty associates.
The University of Iowa and the Office of the Vice President for Research would normally expect key personnel to be named on a funding application routing form whether they are paid or not paid.
Instructions for CITI
To complete the RECR training, complete the following steps:
- Log into CITI through the University of Iowa Link using your Hawk ID and password.
- Scroll to the bottom of the page and click on the “Add a Course” link.
- Check the box for RECR for NSF Faculty and Senior Personnel Training, then click the “Next Button.”
- Click the “Start Now” button to begin the course.
All modules must be completed with a score of 80% or better for each module quiz in order to pass.
UI CITI RECR Course Modules
The UI RECR CITI course for NSF faculty and senior personnel will include the required content as well as some traditional content. The following content is covered under the UI RECR CITI course:
- Research Misconduct
- Conflicts of Interest and Commitment
- Mentoring and Healthy Research Environments
- Peer Review
- Collaborative Research
- Research - Export Controls
- Other Activities – Export Controls
- Introduction to Undue Foreign Influence Impacts and Concerns in Academia
- Reporting, Research Integrity, and Effective Practices to Manage Undue Foreign Influence Risk
Frequently Asked Questions
- Who must complete NSF RECR training?
The CHIPS and Science Act of 2022 amends the America COMPETS Act (42 USC 1862o-1) to require RECR training for faculty and senior personnel, in addition to undergraduates, graduate students and post-doctoral fellows paid off of or listed on NSF awards.
- When does the requirement for faculty and senior personnel to complete RECR begin?
The CHIPS and Science Act of 2022 stipulates that faculty and senior personnel must complete RECR training starting with new proposals submitted or due on or after July 31, 2023. The University of Iowa’s Research Integrity and Security (RIS) Office recommends that all NSF faculty and senior personnel complete training at their earliest opportunity.
- When should RECR training take place?
The America COMPETES Act, the CHIPS & Science Act of 2022 and the National Science Foundation (NSF) do not specify when training must be completed. The University of Iowa’s institutional RCR Plan requires trainees to complete CITI RCR or RECR training within 30 days of being paid on an award, or within 30 days of being notified of funding for an NSF award.
- What topics should be part of the RECR training content?
The CHIPS & Sciences Act of 2022 stipulated that NSF awardees must complete Responsible and Ethical Conduct in Research (RECR) training. The RECR training must include: mentoring and mentor training, awareness of research security risks, Federal export control, and discussion of disclosure and reporting requirements for Conflict of Interest (COI) and Conflict of Commitment (COC). The University of Iowa’s RECR training for faculty and senior personnel also includes: research misconduct, peer review, and collaborative research.
- How should RECR training be delivered? Unlike the NIH, NSF does not specify how training of RECR should occur. Other than the required content specified in the CHIPS & Sciences Act of 2022, the content of training is up to the institution. The University of Iowa has developed, in cooperation with CITI, and a NSF RECR Course for Faculty and Senior Personnel that meets the requirements of the CHIPS & Science Act and provides training in other content deemed to be essential for a well-rounded RECR course.
- How should RECR training be documented?
PI’s/Faculty are responsible for maintaining training records for their federally funded projects. Some institutional compliance administrators have been granted CITI administrator privileges and can access training records if needed.
- How long does RECR training take?
The CITI UI NSF Faculty RECR course has 9 modules with an associated quiz after each module. You must receive a score of 80% or better on all quizzes. The course should take 2-4 hours to complete.
- I have received a compliance notification to complete RECT, but I have already completed the training. What should I do?
If you have received a compliance notification to complete RECR, and you have completed RCR or RECR training in the past 4 years, then please contact the Director of Research Integrity and Security, Mike Andrews (319-335-9687 or email@example.com). He will verify completion of training and can manually update the database to show completion.
- I am an NIH K-awardee faculty member. Can I take the NSF RECR training to satisfy the NIH RCR training requirement?
No. The NIH’s RCR training requirements are stricter than the NSF Faculty and Senior Personnel RECR Training. NIH K-awardee’s, as well as graduate students and post-doctoral fellows, must complete the CITI RCR online training course. Additionally, NIH K-awardees, graduate students and post-doctoral fellows, regardless of federal funding source, must complete mandatory in-person training. The in-person training is satisfied by completing the appropriate approved RCR course through the graduate college
- How does the CHIPS and Science Act of 2022 affect the RECR requirement for NSF funded researchers?
Section 10337 of the Act directed NSF to expand the requirement for responsible and ethical conduct in research (RECR) training to include faculty and other senior personnel on NSF awards. It also specified that training should include: mentoring/mentor training, training to raise awareness of research security risks, Federal export control, disclosure and reporting requirements. In the PAPPG 23-1, NSF has added the mentorship topic and implemented the requirement for faculty and other senior personnel to also complete the RECR training for new proposals submitted on or due on or after July 31, 2023.
- I am a post-doctoral fellow (or undergraduate, or graduate student) paid off an NSF grant. Can I take the NSF Faculty RECR training to satisfy the RCR requirement?
No. The NSF RECR Training Course for Faculty and Senior Personnel is specifically designed for them. It does not contain all the content that undergraduates, graduate students, or post-doctoral fellows are expected to complete under the University of Iowa’s Institutional RCR Plan. Please refer to the UI’s RCR Plan for information on RCR requirements for undergraduates, graduate students and post-doctoral fellows.
- How often do I have to take NSF RECR training for faculty and senior personnel?
The NSF does not have a current requirement for frequency of RECR training. The University of Iowa’s Research Integrity, Security & Compliance (RISC) Office recommends that RECR be taken every 4 years.
- Who oversees compliance of RCR and RECR training?The University of Iowa’s Director of R esearch Integrity and Security, Mike Andrews, is charged with ensuring compliance with federal and institutional requirements with RCR and RECR training. He can be contacted by phone (319-335-9687) or e-mail (firstname.lastname@example.org).
Questions on the formal course requirements may be directed to: Shelly Campo, Assistant Research Integrity Officer and Associate Dean for Administrative Affairs, 319-335-2136 or email@example.com.