Effective: 03/31/2025
Created: 01/04/2009
Responsible Conduct of Research (RCR) fosters ethical principles, professional standards, and best practices guiding researchers to conduct their work with integrity, transparency, and accountability. WashU offers specific RCR online education that encompasses Research Integrity, Mentorship, Study Design & Data Management, Research Security, Authorship & Publication, and Peer Review. Ethical research practices also include principles of human subjects protections, animal welfare, and conflicts of interest. The education requirements related to those principles are covered under separate University policy. The RCR online course satisfies funding agency requirements unless otherwise specified.
It is the policy of the University that the following covered individuals receive RCR education as outlined:
| Funding | Covered Individuals | Required RCR Training | Deadline | Applicable References |
|---|---|---|---|---|
| N/A | All postdoctoral researchers (Scholars and Associates) | Online RCR Training | Within 60 days of appointment | |
| N/A | Clinical fellows engaged in research | Online RCR Training | Within 30 days of engaged in research | |
| NIH | Undergraduates, graduate students, and postdoctoral researchers receiving support on NIH training grants, career awards, fellowships, research education grants, dissertation research grants, or as specified in the NOFO | 8 hours of in-person RCR Training* | Within 30 days of being sourced to the fund(s) | WashU’s NIH Policy on RCR NIH RCR resources NOT-OD-10-019 NOT-OD-22-055 |
| NSF | Undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel supported by the proposed research project | Online RCR Training | Within 30 days of being sourced to the fund(s) | NSF Policy NSF Resources |
| USDA-NIFA | Undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel supported by the proposed research project | Online RCR Training | Within 30 days of being sourced to the fund(s) | USDA-NIFA |
| DOE | PI, PD, Co-PI, Co-PD, project manager; and Other technical staff as required by the DOE (e.g. postdocs, grad students) via funding opportunities and/or the award | Online RCR Training | Prior to proposal submission; and within 30 days for any new individuals added during the course of the award | DOE – FAL 2025-02 |
*NIH requires 8 hours of in-person training per career stage of the individual during the course of the award. Refer to NIH Policy on the Responsible Conduct of Research for details.
Roles and Responsibilities
Principal Investigator
The Principal Investigator (PI) or Project Director (PD) is responsible for fostering an environment of and providing guidance in the ethical and responsible conduct of research for projects and individuals under their supervision. The PI must assure that individuals complete the appropriate education requirements related to the responsible conduct of research, including the requirements outlined within this policy.
School, Department or Program Administration
Schools, departments, and programs are required to ensure compliance with this policy for all research projects they administer through the following actions:
- inform appropriate individuals of their need to comply with this policy
- provide face-to-face programming or referrals to appropriate programming that is discipline and career-level appropriate
- provide appropriate information and resources to enable compliance within the specified timeline for completion
- verify that appropriate individuals have complied with this policy within the applicable timeline for completion
- for in-person RCR education requirements, maintain records to illustrate compliance*
- for any RCR education recorded centrally via Learn@Work, it can be tracked following the RCR Administrator’s Guide)
- implement necessary internal procedures to ensure that outstanding completions are identified and resolved
*Departments conducting in-person RCR sessions for their learners must submit training completions to be recorded in Learn@Work. The department/school must use the RCR Continuing Education Submission Form.
Office of Sponsored Research Services
The Office of Sponsored Research Services (OSRS) is responsible for monitoring and providing institutional assurance of compliance with this policy to all applicable sponsors.
- At the time a proposal is submitted, OSRS certifies the institution has a plan to comply with the regulations governing RCR education. For agencies requiring WashU’s on-line training to be completed at proposal submission, OSRS will verify training completion for the appropriate individuals before submission.
- OSRS monitors compliance with web-based RCR training requirements in Learn@Work on a quarterly basis. OSRS reviews whether individuals have completed their applicable training within the appropriate timeframe. Departments will be notified of instances of non-compliance and must ensure the individuals are compliant within ten (10) days of such notification.
- OSRS will identify unresolved instances of noncompliance and report such issues to the Associate Vice Chancellor for Research Integrity and Ethics.
Office of the Vice Chancellor for Research
The Office of the Vice Chancellor for Research (OVCR) is responsible for providing oversight, educational resources, and institutional compliance with this policy.
Monitoring
Compliance with this policy will be monitored as described herein and may be monitored through additional mechanisms at the discretion of the Vice Chancellor for Research.
Compliance
Issues of non-compliance reported to the Associate Vice Chancellor for Research Integrity and Ethics will be elevated as appropriate to the Vice Chancellor for Research, who is responsible for imposing corrective actions and sanctions.
Failure to gain compliance within the specified timeline and/or circumstances of repeated noncompliance may result in the restriction of project funds associated with the non-compliant individual until compliance is obtained.
Approval
Approved by the Executive Committee on Research on 12/21/2009.
Revisions approved by the Vice Chancellor for Research on 07/31/2023, and 03/21/2025.