September 2024

The University of Virginia Responsible Conduct of Research (RCR) Training Plan outlines the requirements for training and oversight in the responsible and ethical conduct of research among members of the UVA community engaged in research. UVA encourages all faculty, staff, and students conducting research to take advantage of available training in RCR. As a premier research institution, the Office of the Vice President for Research (OVPR) believes it is imperative that we instill basic principles of research integrity and ethics to meet the needs of the University’s research mission. The responsible and ethical conduct of research is critical for excellence as well as for maintaining public trust in research.

Per the National Institute of Health (NIH): The practice of scientific investigation with integrity involves the awareness and application of established professional norms and ethical principles in the performance of all activities related to scientific research.

Per the National Science Foundation (NSF): The responsible and ethical conduct of research (RECR) is critical for excellence, as well as public trust, in science and engineering. The responsible and ethical conduct of research involves not only a responsibility to generate and disseminate knowledge with rigor and integrity, but also a responsibility to:

  • conduct peer review with the highest ethical standards

  • diligently protect proprietary information and intellectual property from inappropriate disclosure

  • treat students and colleagues fairly and with respect.

Per the United States Department of Agriculture (USDA): Institutions that conduct USDA-funded extramural research must foster an atmosphere conducive to research integrity, bear primary responsibility for prevention and detection of research misconduct, and maintain and effectively communicate and train their staff regarding policies and procedures.

Further, training in RCR is a federal requirement for scholars funded by NSF, NIH and USDA NIFA as detailed as follows.

Federal Agency

Minimal Requirement for RCR

Who must complete the training

NIH[1]

At least 8 contact hours of training (RCR training should involve face-to-face interactions and discussion-based coursework, while online training can be a component of the overall training). 

Trainees, Fellows, Postdoctoral Scholars, Graduate Students, Undergraduate Students. Through the notice published in 2010, NOT-OD-10-019, and updates published in 2022, NOT-OD-22-055, the NIH defines the basic principles, policy, instruction components, and other special considerations by award type, applications for individual and institutional awards, reporting requirements and compliance for instruction of RCR.

NSF[2]

CITI RCR training (online option) or discussion-based coursework with minimum content requirement 

All Faculty and Senior Personnel (i.e., principal investigators, co-investigators, and other academic appointees), Undergraduate Students, Graduate Students and Postdoctoral Scholars. Implementation of Section 7009 of the America COMPETES Act 

NIFA

CITI RCR training (online option) or discussion-based coursework with minimum content requirement

Program Directors, Faculty, Undergraduate Students, Graduate Students, Postdoctoral Scholars, any staff participating in the project. Individuals can confirm requirements for their specific project by reviewing the appropriate Terms at USDA-NIFA Terms & Conditions.

[1] Principal investigators submitting NIH grants that require instruction in the RCR are responsible for developing a plan in keeping with the specific requirements for the grant application and NIH guidelines. This includes those applying for NIH training grants and career development awards, including all trainees, fellows, participants, and scholars receiving support from programs such as the following: 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 and any other NIH-funded programs that support research training, career development, or research education and that require instruction in the responsible conduct of research as described in funding opportunity announcements.

[2] Per the NSF, the RCR training requirement flows down all the sub-awardees. See https://www.nsf.gov/pubs/policydocs/rcr/rcrfaqs.jsp#10 for more information.


UVA RCR Policy 

OVPR and each School together ensure that institutional compliance guidelines are met. All students/trainees engaged in NIH/NSF /USDA-NIFA- funded research MUST complete RCR training. Note: some other federal funding agencies, such as NASA, the Department of Energy, and the Department of Education, may also require RCR training as part of the terms for the grant award. Contact the Office of Sponsored Programs at osp-help@virginia.edu or the Director of Research Integrity and Ethics with questions about RCR training requirements. 

The PI is responsible for informing the trainee of the RCR training requirements and assuring that the trainee participates. The trainee is responsible for initiating and completing the training within the required time frame. In particular, the school assures that appropriate RCR courses or programs are promoted to and taken by students when required.

For NSF and NIFA, online RCR training must be completed within 90 days of becoming involved in a project and should be undertaken at least once every four years. For NIH funded individuals, in person RCR training must occur at least every career stage, or once every four years. Unlike NIFA and NSF, NIH allows more time to complete in person RCR training. A common question, RCR training may still need to be completed even if the applicable person has already left the project, because they have been paid from the relevant federal award. The online training must be successfully completed within ninety 90 days of first being appointed to a covered project. Online training requirement must be completed before an applicable person graduates or otherwise leaves the program even if that imposes a shorter deadline.

Non‐compliance on the part of any researcher other than PI or senior personnel, may result in the termination of employment and may result in the disallowance of salary and any associated expenses charged to the sponsored project. Cases of student non-compliance may also be referred to the Dean of Students for additional disciplinary action. 

When a sponsor requires faculty and senior personnel to complete RCR, this training must be complete be completed prior to receiving any financial support from the award. Please note: faculty and other senior personnel subject to the RCR training requirement on NIFA or NSF awards must complete training before OVPR will establish the project account. For changes to personnel and new RCR compliance needs after an award starts, noncompliance by any PI or research staff may also result in suspension of the project account until compliance is assured.

CITI program

The University subscribes to the online Collaborative Institutional Training Initiative (CITI Program) as an RCR training resource available to anyone affiliated with UVA. The CITI grouping of courses/modules in a bundle is slightly different between different learning groups. Learners select the course that most closely aligns with their research focus. Researchers may visit OVPR’s CITI Training webpage to confirm how to access and use CITI. Users choose between the following six categories of RCR training depending upon discipline. 

Biomedical Sciences

Engineering and Computing

Humanities

Physical Sciences

Social, Behavioral, and Education Sciences

Research Administration

Topics Include 

           Introduction to RCR 

           Authorship 

           Collaborative Research 

           Conflicts of Interest and Commitment 

           Data Management 

           Mentoring and Healthy Research Environments

           Peer Review 

           Plagiarism 

           Reproducibility of Research Results 

           Research Involving Human Subjects 

           Using Animal Subjects in Research 

           Research Misconduct 

Electives Include

           Environmental and Social Dimensions of Engineering Research 

           Financial Responsibility 

           Preventing and Responding to Harassment and Bullying in Academia 

           Research Security Training 

           Qualitative Data Analysis 

           Privacy and Data Protection in Data Science 

           Biosafety and Biosecurity 

           Export Control 

Courses for Academic Credit

Certain academic courses may be taken to fulfill the in-person RCR requirements under NIH awards.  For example, BIMS 7100 – Research Ethics is required for the graduate and post-doctoral Graduate Programs and individuals supported by NIH training grants or career development awards. Though it does not cover the full scope of RCR topics required as the BIMS course does, PHS 7840 – Human Subjects Research: Methodology, Ethics and Regulations is available for those interested in participating in a live, interactive course.  Additionally, PHIL 3790 (an undergraduate course that examines the history of research scandal). Academic courses vary in availability for cross registration, not just limited to one school. The catalog of academic courses connected to RCR is constantly changing.

Shared Responsibilities

The responsibility for adhering to sponsor requirements for RCR training and building a culture of ethical and responsible research is shared among those involved in the UVA research endeavor. This includes the principal investigators, schools and departments, and the Office of the Vice Provost for Research (Research Integrity and Ethics and Sponsored Programs). While some responsibilities may overlap, primary obligations of these distinct groups and individuals can generally be described as follows: 

Principal Investigators 

Principal investigators have primary individual responsibility for the conduct and administration of a research grant or contract and must ensure compliance with applicable laws and regulations and institutional policy governing sponsored research. Accordingly, principal investigators must ensure that those supported on their awards complete RCR training per sponsor requirements. Specifically, principal investigators must: 

● identify and communicate with research team members who must receive RCR training;

● determine the most appropriate training format in line with sponsor requirements;

● ensure each research team member completes their training

Schools and Departments

In partnership with the OVPR, schools and departments at UVA should provide support and advice to researchers to foster a community of research excellence as follows:

● integrate research ethics and integrity discussions in regular meetings of the school or

department as a means of raising awareness and fostering a culture of integrity at the 

highest administrative level across the school or department and within the individual  

research teams;

● help educate principal investigators as to their mentoring and support role for RCR training; offer in-person training by departments or the school

● provide support for face-to-face RCR training relevant to the trainee’s specific discipline and career stage; 

● share RCR information and resources across UVA to assist new researchers or trainees in adhering to training requirements and expectations; 

Office of the Vice President for Research

The Office of the Vice President for Research assumes responsibility for the following as part of its function to support the ethical and responsible conduct of research activities at UVA: 

● maintain and update the UVA RCR plan and related webpages;

● offer educational sessions, including a newly developed RCR seminar series;

● provide information to sponsors regarding compliance on request;

● allocate resources for oversight, including monitoring of completion of training, and

coordination of RCR training opportunities in concert with UVA Schools and departments;

● review and approve previously completed RCR training and proposals for new RCR training content on a case-by-case basis;

● verify compliance with RCR requirements, tracking record of training completion 

● partner with Departments and Schools to promote faculty engagement in building a culture of ethical and responsible research.

Sponsored Programs 

The Office of Sponsored Programs Authorized Organizational Representative is responsible for providing institutional assurance of compliance to applicable funding agencies.

 This includes:

● at the time of an NSF proposal submission, certify that the institution has a plan to provide appropriate training and oversight in the responsible and ethical conduct of research;

● at the time a notice of award is processed, provide a reminder to the principal investigators and research administrator that the award is subject to RCR training requirements;

● at time of subaward, communicate applicable RCR requirements to subawardee(s) and the Principal Investigators

Failure to Complete RCR Training and Consequences

Failure to comply with applicable RCR training requirements violates sponsor award terms and conditions as well as UVA policy RES-011, Investigator Eligibility Requirements and Responsibilities Related to Sponsored Programs.

All undergraduates, graduate students, and other trainees involved in research are encouraged to take basic RCR training. Failure to complete the CITI training in the designated time, may result in the students removal from the award, suspension of research activities, and potential loss of compensation. 

Failure to complete all required online RCR training within 90 days may result in suspension of grant funding and support, which includes stipend, tuition, fees, travel, supplies, etc. To have funding reinstated, the individual must complete (or retake) CITI RCR on-line training and/or enroll in an approved academic in-person RCR Course. Only after CITI RCR training has been successfully completed/retaken or registration for an approved RCR Course may funding be restored.

Transfer Training from Former Institution

If you have completed the CITI RCR course within the last four years at your former institution, you can transfer your completed modules from another institution to UVA Please follow the directions below:

  • Go to the CITI homepage: https://www.citiprogram.org/portal?site=660

  • Login using your existing credentials.

  • Click on the “Add Institutional Affiliation” link under Institutional Courses.

  • Choose “University of Virginia” from the drop-down menu.

  • If you have completed the CITI RCR course at your previous institution, you can select the RCR course you have already taken when you update your affiliation to UVA. Once transferred, you should see the RCR course in your UVA Previously Completed Coursework.

  • Once you have affiliated your course, you will see which required modules you have received credit for from your previous institution. You may still need to complete additional modules to meet UVA RCR requirements.

Records

OVPR receives records when online RCR training has been completed. Electronic records are available for review by OVPR and investigators. OVPR is responsible for this overall RCR plan, any related policies and procedures, and for providing information to sponsoring agencies regarding compliance with RCR training.

Maintenance of RCR Content

RCR content will be reviewed at appropriate intervals and modified 1) to include new material such as pertinent discipline specific case studies and 2) to remove outdated or obsolete information. OVPR will conduct audits of the RCR program and courses to evaluate the overall training process, monitor effectiveness, and create opportunities for content/process improvement.  OVPR, through the Research Integrity Officer (RIO), will ensure compliance with the RCR Plan.