[Office-of-research] NSF's Implementation of Section 7009 of the America COMPETES Act

Bruce Morgan bruce.morgan at ucr.edu
Wed Aug 26 21:48:20 PDT 2009

To:  NSF Principal Investigators and Department Contract and Grant Analysts


From:  Vice Chancellor for Research Charles Louis


Two years after President George W. Bush signed into law the America
Competes Act (ACA), which was designed to improve U.S. competitiveness in
mathematics and science, the National Science Foundation has announced its
plans for requiring that grantees implement a training program for the
"responsible and ethical conduct" of research.  This requirement mandates
that all undergraduates, graduate students, and postdocs supported in whole
or in part with NSF awards receive this training.  It is important to note
that the research administration community vigorously protested to Congress
because it was recognized that this requirement is a mandate with real costs
but without any increase in indirect cost funds to enable implementation and


At a meeting in April hosted by the Office of Research, to which all NSF
Principal Investigators were invited, I learned that some graduate programs
already have a one credit course for all new graduate students and it
appears that these courses could form a part of the required training
program.  I attach the slides I had for that meeting.  As you can see, the
content of what this program could include is much broader than just
"research ethics" that could be delivered by an online course/power point
presentation plus a test.  In fact, NSF officials have made public
statements to the effect that a web-based only solution to this requirement
would not be sufficient.


The NSF published its rule for complying with Section 7009 of the ACA in the
August 20, 2009 Federal Register
(http://edocket.access.gpo.gov/2009/E9-19930.htm).  The rule applies to all
proposals submitted to NSF on or after January 4, 2010, and requires that
institutions certify that they have a research ethics training program in
place and that all undergraduates, graduate students, and postdocs supported
in whole or in part with NSF awards receive this training.  


The Office of Research will continue to sponsor some activities such as the
grant writing workshop this year by a former NIH program officer - and we
will provide links to all the materials NSF has committed to make available
through their Web site.  We will also develop a listing of other on-line and
text materials that units could use in meeting this requirement.  However,
training needs may vary between academic disciplines, specific circumstances
of research, or the needs of undergraduates versus graduate students and
postdocs.  Consequently, the responsibility for developing such a training
program and maintaining information on the students and postdocs who have
completed a program will largely rest with departments and programs. 


To comply with this new regulation, all proposals submitted to NSF on or
after January 4, 2010 must include the required certification.  To ensure
that the Office of Research is appropriately making this certification,
proposals submitted to Sponsored Programs will need to be accompanied by a
brief description of the research ethics training program the
PI/department/program has developed or plans to develop by the time of the
award for all undergraduates, graduate students, and postdocs that will be
supported by this NSF award, and the procedures that will be used to track
that this training has occurred.  This documentation should be uploaded to
the eCAF for each NSF proposal and should be appropriately labeled (e.g.,
research ethics training.doc, ethics training.doc, etc.).  Without this
documentation, the Office of Research will not be able to make the required
certification to the NSF, nor will they be able to submit the proposal to
NSF until the documentation is received.  In addition, Principal
Investigators and the units administering their NSF awards will be
responsible for maintaining and retaining documentation that provides
evidence that the research ethics training was received by all
undergraduates, graduate students and postdocs supported in whole or in part
with NSF funds. This documentation will be essential for demonstrating
compliance with this new requirement to internal or external audits of this
new certification.


The Office of Research will be updating PIs and units as the NSF provides
additional information about this new requirement and its implementation.
In addition, we will be announcing another meeting to be held later in
September for all NSF Principal Investigators (applicants and awardees) and
department analysts to answer questions about this new NSF requirement.

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