Sponsored Programs and Research Services

National Science Foundation Responsible and Ethical Conduct of Research (RCR) Education Requirement

This Policy applies to:

  • Current National Science Foundation Principal Investigators (if Award is based on a Proposal Submitted 1/4/10 or later); and
  • Faculty & Staff Submitting Proposals to the National Science Foundation

The National Science Foundation (NSF) has implemented Section 7009 of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science (COMPETES) Act with an effective date of January 4, 2010. This Section requires that each institution that applies to the NSF for financial assistance has a plan to provide appropriate training and oversight in the responsible and ethical conduct of research (RCR) to undergraduate students, graduate students, and postdoctoral researchers who will be supported by NSF. The University is required to certify, at the time of proposal submission, that a plan to provide this training is in place. It is further required to verify that those supported by NSF have actually received this training. Achieving compliance with this requirement will involve cooperation between the Sponsored Programs and Research Services (OSPR), Principal Investigators (PI), undergraduate students, graduate students, and postdoctoral researchers. This training is required if an award is received based on a proposal submitted on January 4, 2010 or after.

Cleveland State University’s response to meet this requirement is to provide web-based RCR training for all students and postdoctoral researchers supported by the NSF. This training will be provided by the Collaborative Institutional Training Initiative (CITI) and is available at the following website: https://www.citiprogram.org (see CSU CITI RCR instructions). The University may expand this requirement to all undergraduate students, graduate students, and postdoctoral researchers in the future.

Please be aware this requirement only applies to those conducting research. This excludes, for example, conference, symposium, workshop, or travel proposals. This also excludes individuals who are considered “participants.” For example, individuals receiving only scholarship or stipend support to enroll in an academic program are not required to receive RCR training. However, students must take RCR training if they receive NSF scholarship or stipend support to engage in research, or if conducting research is included in their academic program. At Cleveland State University, this would include graduate students receiving a stipend and/or tuition support as part of a graduate assistantship charged to an NSF research grant.


Upon receipt of an award that falls under this requirement, the Sponsored Programs and Research Services (OSPR) will notify the Principal Investigator (PI) and all identified undergraduate students, graduate students, and postdoctoral researchers of this policy. It is also expected and required that the PI will notify all parties subject to this policy as they are identified during the lifetime of the grant. The individual must complete the training by either:

  1. The end of his/her first year of involvement;
  2. Before the overall project end date (if joining project
  3. Before his/her involvement terminates (if joining project for limited duration, e.g., Summer REU (Research Experience for Undgraduates) program).

In summary:

 #  Step Responsible Party When
1 Notify PI and all named US, GS, and PDR of RCR requirement. SPRS Upon Award Receipt
2 Notify SPRS of any additional US, GS, or PDR supported by NSF project. PI Ongoing
3 Complete RCR training US, GS, PDR Project Period > 1 Year: Within 1st Year of Involvement
Project Period
4 Prompt US, GS, PDRs to complete RCR training PI Ongoing
5 Prompt US, GS, PDRs to complete RCR training (copy to PI) SPRS Project Period > 1 Year: at 6 months
Project Period
US = Undergraduate Students               PI = Principal Investigator
SPRS = Sponsored Programs and Research Services               PDR = Postdoctoral Researchers
GS = Graduate Students

Record Keeping

Documentation of the online CITI training should be maintained by the individual taking the training and the PI. Pursuant to the University’s standard record retention policy for sponsored programs, these records must be maintained for five (5) years after the final expenditure report is submitted to the sponsor. SPRS will be responsible for monitoring compliance with this policy and RCR training documentation will be required as part of the project close-out process.


The CITI website will automatically notify SPRS when training has been completed and SPRS will update its records accordingly. For a standard grant, if SPRS does not receive this notification within the first six months of an award, it will notify the individuals that the training must be initiated. In addition to the deadlines stated above (see chart), the CITI website requires that training be completed within three months once initiated.