OIG Response to OMB

Dear Ms. Mar,
Thank you for the opportunity to address your questions. The America COMPETES
Act required
each institution that applies for financial assistance from the
Foundation for science and engineering research or education describe
in its grant proposal a plan to provide appropriate training and
oversight in the responsible and ethical conduct of research to
undergraduate students, graduate students, and postdoctoral
researchers participating in the proposed research project.
NSF implemented this by the following (applicable to grants awarded after January
4, 2010):
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.
NSF’s implementation raises several questions we expect this review to address,
namely,
i)

What, if any, is the impact of NSF’s decision to alter the focus of RCR
training from those who participate in NSF research (as stated in the
COMPETES Act) to only training those who are directly supported by
NSF funding? One consequential example is if a PI had two students
working in the lab participating in NSF-funded research, but only one is
supported by the grant and the other not, then only that one would
require RCR training.

ii)

NSF requires appropriate training, but allows grantees to define what is
appropriate. By gathering the grantee’s plans, we can assess various
methods by which grantees are meeting the requirement and identify best
practices as well as practices we believe may be problematic. If a
significant number of plans implement practices which are problematic,
NSF can consider whether it should put forth guidance on what defines
appropriate training. (Queries from subjects of our research misconduct
investigations and one comment from the Federal Register (Commenter 1)
would indicate yes

iii)

Do institutions want more guidance or do they like having no
requirements for course structure and content? As an example, NIH also
requires RCR training, but has specific guidance about what it expects in
an RCR program. Since grantees have to comply with both programs, we
would like to know how grantees meet the disparate requirement of both
agencies and whether a more unified approach would better serve NSF
and the grantees. We also want to assess whether having two programs
causes more of a burden for grantee institutions.

We hope this clarifies the purpose of our oversight review (not an audit). As you can
see, we are interested in not only whether grantees minimally comply with the
requirement, but how they do comply. As we responded to Commenter 3 (Federal
Register Vol. 78, No. 105, May 31, 3013, p. 32694), we are not conducting an RCR
audit to determine the effectiveness of the program, nor are we requiring the
grantees do so.
In your second paragraph, you raised a number of questions. As you will note from
NSF’s implementation, it does not require each proposal to include an RCR plan.
Thus, grantee institution will have a single plan, rather than a different plan for
each proposal. We will be requesting that plan as part of our initial document
request (see our sample engagement letter Appendix A1 of our package).
We hope this background on the COMPETES Act and NSF’s implementation, and
the differences in the two, along with our elaboration of our goals answers your
questions about the purpose of our review. If you have any other questions, please
contact us.