Version Number: 3.0
Effective Date: January 1, 2010
Latest Update: July 21, 2023
Title: Princeton University Responsible Conduct of Research Policy
Background
The University believes that training in the responsible conduct of research (RCR) is an essential component of graduate education and postdoctoral training. The National Science Foundation (NSF), a major source of Princeton's federal research funding, advocates a similar philosophy: "The responsible and ethical conduct of research (RECR) is critical for excellence, as well as public trust, in science and engineering." Similarly, the National Institutes of Health (NIH) holds as a core principle the belief that "responsible conduct of research is a fundamental element of research training."
In 2010 when this policy was first implemented, the University committed to training all graduate students and postdoctoral researchers in the social sciences, natural sciences and engineering, and any other individuals who must satisfy training requirements specific to federally sponsored research. As part of this commitment to graduate education, an introductory RCR training module is being added to the training program for graduate students across all divisions, including humanities. The RCR training program as it is currently designed meets requirements from funding agencies, specifically the National Science Foundation (NSF), National Institutes of Health (NIH), and the US Department of Agriculture (USDA-NIFA), while providing flexibility to meet trainees' pedagogical needs, which can vary by discipline and trainee population.
Policy
Princeton's policy is to provide education in the responsible conduct of Research (RCR) to graduate students and postdoctoral researchers proactively as an important element in their training, and to faculty, undergraduate students, and other research personnel in compliance with requirements of federal research sponsors.
Who is Affected by this Policy
- Graduate students pursuing research-based master's programs or doctoral education
- All postdoctoral researchers (postdoctoral research fellows and postdoctoral research associates) in the divisions of social sciences, natural sciences and engineering
- Undergraduate students, visiting student research collaborators (VSRC), and any other short-term researchers who are supposed by grants with RCR training requirements
- Faculty and other senior personnel conducting research supported by grants with RCR training requirements
Responsible Executives
Dean for Research
Dean of the Graduate School
Dean of the Faculty
Responsible Offices
Office of the Dean for Research
Office of Research and Project Administration
Office of the Dean of the Graduate School
Office of the Dean of the Faculty
Contact Information
Elizabeth Adams
Director
Office of Research and Project Administration
619 Alexander Road, Suite 102
e-mail: [email protected]
Tel: 609-258-3090
Fax: 609-258-1159
Alice Seneres
Associate Dean for Academic Affairs
Office of the Dean of the Graduate School
005 Clio Hall
e-mail: aseneres@princeton.edu
Tel (609) 258-4959
Fax (609) 258-6180
Kristine Ryan
Assistant Dean of Compliance
Office of the Dean of the Faculty
206 Stanhope Hall
email: [email protected]
Tel (609) 258-2396
Undergraduates should seek advice from their home department as each department requirement varies.
University RCR Training Plan
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The University believes RCR instruction is good professional development for all graduate students. Thus, the University plan assumes and expects that graduate students pursuing research-based master's programs or doctoral education will benefit from learning RCR concepts at the outset of their graduate education.
An RCR introductory module will be given to all incoming doctoral and research-based master's students in order to provide them with an overview of the expectations or conducting research responsibly and to provide them with resources for learning more about RCR topics.
Graduate students pursuing doctoral education in the natural sciences, engineering, and the social sciences are expected to complete additional training by taking a full RCR course, regardless of the mode of funding expected in the later years of study. The full RCR course shall be taken within the first three (3) years of study. RCR courses must be discipline-specific, covering issues and problems that graduate students are likely to encounter during their research experience. Courses offered by departments, or related clusters of departments, should be taught by one or more departmental or program faculty. Graduate-level RCR courses are reviewed and approved by the curriculum subcommittee of the Graduate School, which is composed of faculty representatives from all four academic division. The curriculum subcommittee is charged with the review and approval of all permanent graduate courses, including RCR courses.
In some circumstances, such as a student departing the program early or a department approved for an online training course, online modules supported by the University are an appropriate and sufficient training platform. In other cases, portions of online training modules may be utilized as a resource for the regular courses. Some federal agencies require in person courses, while others accept either online or in person formats.
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The University expects that postdoctoral researchers in the natural sciences, engineering, and the social sciences take an appropriate RCR course designated by their department or program within the first six months of their appointment. Even if a postdoctoral researcher received RCR training in their previous career stage as a graduate student, RCR training as a postdoctoral researcher at Princeton is still required.
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These categories of students and researchers may receive support from federal grants with RCR training requirements. As these individuals contribute to the research project for shorter and less predictable periods of time, all such individuals shall complete the full RCR course training prior to being supported by the award or within the year after the support begins. Training may consist of either an appropriate course or asynchronous online program, provided the training satisfies federal sponsor requirements.
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The University requires that faculty and senior personnel complete RCR training in accordance with sponsored research award requirements. An online training module for faculty and senior personnel is now available, with an expectation that the training be completed prior to or within six months after initiation of a federally funded award with RCR training requirements.
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To facilitate training and compliance, the University subscribes to the online Collaborative Institutional Training Initiative (CITI Program) as an RCR training resource available to anyone affiliated with Princeton University. The training materials may serve as supplemental training resources or, when appropriate to the situation and population being trained, as the designated platform for the full RCR course. Four basic courses, designated by disciplinary focus, are available: Social Sciences and Humanities Researcher, Physical Sciences Researchers, Life Sciences Researcher, and Engineering Researcher. Learners select the course that most closely aligns with their research focus. A fifth, optional course is available for research administrators.
Sponsored Research Requirements
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As trainees, fellows, participants, and scholars receiving support through any NIH training, career development award (individual or institutional), research education grant, and/or dissertation research grant must receive instruction in the responsible conduct of research. Such training is considered to be a fundamental element for conducting research supported by the NIH mechanisms listed below. This NIH policy took effect with all new and renewal applications submitted on or after January 25, 2010, and for all continuation applications with deadlines on or after January 1, 2011, as set for in NOT-OD-10-019. Updated recommendations on the format of instruction, frequency and timing, and subject matter were incorporated in NOT-OD-22-055 for grants beginning with September 25, 2022 due dates.
The requirement applies to the following programs: 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. This policy also applies to any other NIH-funded programs supporting research training, career development, or research education that require instruction in responsible conduct of research as stated in the relevant funding opportunities.
Additional information and guidance are available from the NIH Central Resource for Grants and Funding Information on Research Integrity.
The NIH requires substantive "face-to-face" discussion as part of the training course. Video conferencing options may be incorporated into RCR instruction, thought it should not be the sole means of instruction, "except in special instances of short-term training programs, or unusual and well-justified circumstances." Normally, asynchronous online training will not satisfy the NIH training requirement.
NIH provides the following list of topics traditionally incorporated into most acceptable plans for RCR training, and additional topics (in bold) that merit inclusion based on developments in the conduct of research and a growing understanding of the broader research environments.
- 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.
- Secure and ethical data use: data confidentiality, management, sharing, and ownership
- Conflict of interest - personal, professional, and financial and conflict of commitment, in allocating time, effort, or other research resources
- Research misconduct and policies for handling misconduct
- Responsible authorship and publication
- Peer review, including the responsibility for maintaining confidentiality and security in peer review
- Collaborative research, including collaborations with industry with industry and investigators and institutions in other countries
- Mentor and mentee responsibilities and relationships
- Policies regarding human subjects, live vertebrate animal subjects in research, and safe laboratory practices
- The scientist as a responsible member of society, contemporary ethical issues in biomedical research, and the environmental and societal impacts of scientific research
- Safe research environments (e.g., those that promote inclusion and are free of discriminatory harassment)
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The American Creating Opportunities to Meaningfully Promote Excellence in Technology Education, and Science (COMPETES) Act, Section 7009, requires that institution receiving funding from the NSF for research and education have a plan to provide training and oversight in the responsible and ethical conduct of research (RECR) to personnel supported by funded awards. Proposals submitted after January 4, 2010, require training for all participating undergraduate students, graduate students, and postdoctoral researchers. For proposals submitted or due on or after July 31, 2023, the training requirement has been extended to include faculty and other senior personnel.
Additional information and guidance can be found at NSF - Responsible and Ethical Conduct of Research. The NSF Proposal & Award Policies & Procedures Guide (PAPPG) includes the most up to date information on instructional expectations and subject matter requirements.
The NSF allows for in-person training or online training to complete the RECR requirement. Training should be tailored to the discipline with appropriate and relevant topics.
NSF expects the responsible and ethical conduct of research to include the following responsibilities, at a minimum:
- Generate and disseminate knowledge with rigor and integrity;
- Conduct peer review with the highest ethical standards
- Protect proprietary information and intellectual property from inappropriate disclosure;
- Treat students and colleagues fairly and with respect; and
- Include mentor training and mentorship in RCR training.
New requirements to include training on research security threats and export control, disclosure and reporting requirements are expected to on into effect for new proposals submitted or due on or after July 31, 2023. NSF, however, encourages the community to establish such training and oversight for faculty and other senior personnel prior to the July 31, 2023 implementation.
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All undergraduate students, graduate students, postdoctoral researchers, faculty, staff, and program directors receiving support through any USDA-NIFA award must receive instruction in the responsible conduct of research.
Additional information and guidance can be found at USDA-NIFA - Responsible and Ethical Conduct of Research.
The USDA-NIFA allows in-person training or online training to complete the RCR requirement. USDA-NIFA lists the following subject to be included in RCR training, at a minimum:
- Authorship and plagiarism
- Data and research integration
- Reporting misconduct
Roles and Responsibilities
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ensuring the timely RCR training of senior personnel and non-senior personnel (including undergraduate students and other short-term researchers) who are conducting research supported by grants with RCR training requirements, and
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completing RCR training themselves on a timely basis, when conducting research supported by grants with RCR training requirements.
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- creating, gaining approval from the Graduate School, and staffing the RCR course or courses, as appropriate;
- providing timely notification to senior personnel, postdoctoral researchers, graduate students (including those enrolled in research master's programs), undergraduate VSRCs, and other short-term researchers who are supported by awards with RCR training requirements of the requirement to complete RCR training and of the approved RCR course(s) designated for their population;
- ensuring that the relevant individuals who are supported by awards with RCR training requirements complete appropriate RCR training courses within the relevant time frames;
- certifying, through the annual re-enrollment process, which graduate students have completed their RCR training;
- identifying and notifying individuals who are not in compliance with the training requirement of their responsibility to complete training, and escalating noncompliance to department leadership; and
- removing charges from grants for individuals who did not complete RCR training on time.
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- providing the introductory RCR training module to graduate students in all division,
- reviewing and approving departmental RCR courses, and
- tracking, documenting and notifying academic departments on student compliance with RCR training.
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- certifying that the institution has an RCR training and oversight plan to support the submission of federal funding applications,
- collecting, maintaining and making available records related to RCR training plans and compliance under relevant sponsored awards,
- providing these records to grant agencies upon request to review training plans, and
- taking necessary administrative actions to ensure compliance with sponsor requirements and grant terms and conditions.
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including training requirements in offer letters for all incoming postdoctoral researchers.
Other Resources
Applicable Individuals
In Labor Accounting, when allocating salary to chartstrings with RCR training requirements, the following alert will pop-up:
"Applicable Individuals must complete Responsible Conduct of Research (RCR) training to be paid from Project XXXXX. Non-compliance may result in the removal of all support for this individual. Resources: RCR status report in the Information Warehouse, RCR requirements and training options on the ORPA website."
Applicable Individuals include:
- Graduate Students
- Post-doctoral Researchers
- Faculty / Senior-Key Personnel
Updated Log
- 1/13/2015: General language cleanup and updates to federal agency information.
- 5/9/2023: Re-written in the format of the University policy template and to improve clarity;added new requirements from federal sponsors, notably expectations regarding subject areas and training for faculty and senior personnel; added requirement for introductory RCR training for doctoral and research-based master's graduate students in all divisions.
- 6/12/2023: Administrative update to the USDA-NIFA section to reflect agency requirements.
- 7/1/2024: Updated faculty and other senior personnel RCR training tab to announce online CITI training is now available and provided a link to the training.