National Postdoctoral Association

RCR TOOLKIT
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Overview
The 2007 America COMPETES Act directed NSF to require that all funded students and postdocs undergo training in the responsible conduct of research (RCR). The implementation of this requirement becomes effective January 4, 2010, when all institutions submitting proposals to NSF must certify that they have a training plan in place for undergraduate and graduate students and postdoctoral scholars who will be supported by NSF to conduct research. This certification must be in place at the time of proposal submission. Training plans need not be submitted with the proposal, however, they must be provided for review upon request. Institutions are responsible for verifying that their undergraduate students, graduate students and postdoctoral scholars receive training.

These guidelines are enumerated in detail in the January 2010 NSF Proposal and Award Policies and Procedures Guide, specifically in Part I - Grant Proposal Guide, Chapter II. C.1e and in Part II - Award and Administration Guide, Chapter IV.B. Additional details on the implementation, including responses to the concerns submitted by the community during the open comment period, are included in the Federal Register Notice of August 20, 2009 (Volume 74, Number 160). The pertinent excerpts from these sections are quoted later in this article.

Developing an RCR Training Plan
The NSF has stated that it does not intend to release guidance or standards on what should be included in a training plan. In the Federal Register Notice of August 20, 2009, the agency emphasized the need for institutions to tailor their training to the needs, diversity and intended careers of their students and postdocs. It encouraged institutions to determine their own plan for both content and delivery, although this might include newly developed resources as well as use of existing materials. This differs somewhat from the required RCR training of biomedical trainees supported by National Institutes of Health (NIH) training grants, which has long adopted the nine core content areas recommended by the federal Office of Research Integrity at the Department of Health and Human Services: Data Acquisition, Management, Sharing and Ownership; Conflict of Interest and Commitment; Policies Regarding Human and Animal Subjects; Research Misconduct; Publication Practices and Responsible Authorship; Mentor / Trainee Responsibilities; Peer Review; Collaborative Science; and the Scientist as a Responsible Member of Society[*].

Institutions developing training plans for their postdoctoral scholars therefore should be responsive to the unique needs of these early-career researchers. Many postdocs have not received formal training in RCR, and this is more often true for international postdocs who comprise the majority of postdocs working in the U.S. Any training program should be cognizant of the breadth of cultural diversity among postdocs, and among graduate students, and that some cultural and research norms may differ; for example, the norms for attribution, record keeping and assignment of authorship. The NPA finds that postdocs are more likely to engage in a program that has clear  implications for career development. When designing a training curriculum, consider embedding ethics issues alongside training in research and professional development topics, such as authorship practices with scientific publishing tips or peer review principles with grant writing guidance. Finally, take into account other unique issues for postdocs, such as the implications of short-term appointments on data ownership, the dual role they fill of both mentor and mentee, and postdocs' dependence upon their supervisor for career advancement, which can influence conflict management in the lab/research group. Guidance on these needs and approaches for establishing effective training programs for postdocs can be found in the NPA's RCR Toolkit.

Some additional suggestions:

1. Find out how NIH-funded trainees on training grants satisfy their RCR training requirement. You may be able to generalize this training to include NSF-funded trainees.

2. Consult the NPA's RCR Toolkit, in particular, the Quick Start Guide, RCR Topics for Postdocs, and Sample curricula, agenda and course materials.

3. When released, consult the forthcoming NSF's RCR education clearinghouse.

Excerpts from NSF Guidelines:

Implementation Plan from Federal Register Notice:

Implementation Plan: Effective January 4, 2010, NSF will require that, at the time of proposal submission to NSF, a proposing institution's Authorized Organizational Representative certify that the 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 by NSF to conduct 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. NSF will formally implement the new RCR requirement via an update to the NSF Proposal and Award Policies and Procedures Guide (PAPPG). It is anticipated that the revisions to the PAPPG will be issued on October 1, 2009. NSF also will modify its standard award conditions to clearly stipulate that institutions are responsible for verifying that undergraduate students, graduate students, and postdoctoral researchers supported by NSF to conduct research have received RCR training. In addition, NSF will support the development of an on-line RCR resource containing research findings, pedagogical materials, and promising practices regarding RCR in science and engineering. The development and evolution of the ongoing online RCR resource will be informed by the research communities that NSF supports, and it will serve as a living resource of multimedia materials that may be used to train current and future generations of scientists and engineers in RCR.

From January 2010 Award & Administration Guide (AAG), Chapter IV.B, Page IV-3:

2. Institutional Responsibilities

a. An institution must have a plan in place 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 by NSF to conduct research. As noted in GPG Chapter II.C.1.e, institutional certification to this effect is required for each proposal.

b. 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.

c. An institution must designate one or more persons to oversee compliance with the RCR training requirement.

d. Institutions are responsible for verifying that undergraduate students, graduate students, and postdoctoral researchers supported by NSF to conduct research have received training in the responsible and ethical conduct of research.

From January 2010 Grant Proposal Guide (GPG), Chapter II.C.1e:

• Certification Regarding Responsible Conduct of Research (RCR): The AOR is required to complete a certification that the institution has a plan16 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 by NSF to conduct research.
  
  Additional information on NSF's RCR policy is available in the AAG, Chapter IV.B. 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.

[*]Note that NIH has recently updated its requirements on RCR training, including the addition of the last recommended RCR topic: "the scientist as a responsible member of society, contemporary ethical issues in biomedical research, and the environmental and societal impacts of scientific research." For more information, see: http://www.grants.nih.gov/grants/guide/notice-files/NOT-OD-10-019.html.

References:

NSF Federal Register Notice on RCR Implementation: Federal Register Notice of August 20, 2009 (Volume 74, Number 160)

NPA RCR Toolkit: http://www.nationalpostdoc.org/rcr-toolkit

ORI's RCR Education Materials Clearinghouse http://ori.dhhs.gov/education/products/

National Academy of Engineering Workshop Report: Ethics Education and Scientific and Engineering Research: What's Been Learned? What Should be Done? http://www.nap.edu/catalog.php?record_id=12695