Plan for NSF Compliance


Case Western Reserve University (CWRU) complies with Section 7009 of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science (COMPETES) Act.

The responsible and ethical conduct of research (RCR) is critical for excellence, as well as public trust, in science and engineering. Consequently, education in RCR is essential in the preparation of future scientists and engineers.

Accordingly, the university has implemented 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 research projects supported by the National Science Foundation (NSF).


All undergraduates, graduate students and postdoctoral researchers who receive salaries, wages, or stipends from an award associated with an NSF-sponsored project will complete RCR training.

Students who only receive scholarship or stipend support to enroll in an academic program through such NSF programs as S-STEM and Noyce are not required to receive RCR training; however, all students must take RCR training if they receive NSF scholarship or stipend support to engage in research, or if conducting research is a part of their academic program.

In addition, the RCR training requirement flows down to all subawardees, at any tier. Therefore, the Office of Research Administration will ensure that these RCR requirements are appropriately addressed in the subaward instrument.


The Office of Research Administration’s Authorized Organizational Representative will certify at the time of proposal submission 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. Once a proposal has been submitted, an email will be sent to the PI, informing them that, in the event of funding, all students and postdocs required by the policy must complete RCR training.

If the proposal is funded, the internal Notice of Award will include a notification of the RCR training requirement. The PI is responsible for informing the students/postdocs that each must log into the CITI online training program and complete the modules contained in the RCR tutorial appropriate for the type of research they will conduct (biomedical, social and behavioral, physical science or humanities). Training must be completed within 60 days of the first time the student/postdoc’s salary is charged to the NSF project.

A database of the names of NSF-supported students/postdocs is maintained by the Office of Research Administration. A coordinator is assigned responsibility for maintaining and updating the database under the direction of the Director of Research Integrity and Education. The coordinator receives automated completion reports from CITI and will update the database regularly. On the first business day of each month, the coordinator reviews the database and sends reminders to any individuals required to complete the training who have not yet done so. The PI will be copied on the email reminders.

If the student/postdoc does not complete the training within the required time period, an escalating notification system will be used to remind the PI and the student/postdoc of this obligation. Failure to complete the training within 60 days of salary charged to the grant will result in the NSF funding being stopped for that individual, all related costs will be removed from the project and no further work can be done by that individual on the NSF project until training has been completed and verified by the coordinator.

Oversight Official

CWRU has designated the Vice President for Research, Dr. Suzanne Rivera, to oversee compliance with the RCR training requirement.

Recommendation for Additional Supplementary Training

Supplementary training in RCR also is recommended. While the online training provides excellent introductory knowledge, NSF has indicated that face-to-face, small group training also should occur.

The university recognizes the importance of maintaining flexibility with regard to the modes of delivery for supplementary training. As such, the following guidelines are provided:

  • The PI should engage in interactions that include substantial focus on the core areas of RCR, as appropriate to the research being conducted.
  • Suggested interactive formats include discussion of case studies and journal clubs.
  • Large, auditorium-style seminars can be appropriate, but follow-on small group discussions are strongly encouraged.
  • Medical school trainees on applicable grants will be asked to take IMBS 500.
  • For trainees funded on short-term assignments, alternative programming may be acceptable. For individuals supported for longer than two years, continuation of training is expected.
  • Supplementary training can be incorporated into existing research methods courses or laboratory meeting schedules.
  • PIs should keep documentation on all supplementary training activities conducted throughout the year.