The National Science Foundation (NSF) requires grantee institutions to have a plan to provide appropriate training and oversight in the responsible and ethical conduct of research (RCR) to all faculty, principal investigators, co-principal investigators, senior personnel, undergraduate students, graduate students, and postdoctoral researchers who are conducting research and paid from a NSF grant awarded directly to the institution or as a sub-recipient.

Effective July 31, 2023: The NSF expanded the Responsible and Ethical Conduct of Research (RCR) training requirement to include all faculty, principal investigators, co-principal investigators, and senior personnel.

This requirement can be found in the NSF Proposal and Award Policies and Procedures Guide (PAPPG), NSF 23-1, dated January 30, 2023.

Effective July 31, 2023

All faculty, principal investigators, co-principal investigators, senior personnel, undergraduate students, graduate students, and postdoctoral researchers who are conducting research and paid from an NSF grant awarded to UVM directly or as a subrecipient are required to complete the Responsible Conduct of Research (RCR) - Basic Training Course offered on-line through the CITI Program. The CITI RCR Basic Course covers all essential RCR topics.

• RCR Training should be completed within the first 3 months on the project.
• RCR Training is completed once.
• RCR Training satisfies both the NSF and USDA/NIFA RCR Training requirement.
• Research Integrity will notify individuals by email and provide CITI login instructions.
• RCR email reminders will be sent monthly to only those that have not completed RCR Training.
• Once RCR Training is complete the email remiders will stop.
• The PI of the NSF award will be copied on all emails, keeping them informed about who on their grant needs RCR training.
• When needed, Research Integrity will request assistance from the PI to help push along all those that remain delinquent in completing the RCR training.
• RCR Exceptions: If the PI believes there is an individual that does not meet the RCR requirements they may request to have the RCR requirement removed. Requests must be emailed to the RCR Coordinator and please provide a reason for the exception (i.e: the individual is not conducting or participating in the research, conference, travel, workshop, or symposium specific award).
• UVM RCR Coordinator, Nicole Schwartz or Brian Prindle (rcr@uvm.edu).

• RCR email reminders will be sent monthly to only those who have not completed RCR Training.
• Once RCR Training is complete the email remiders will stop.
• The PI of the NSF award will be copied on all emails, keeping them informed about who on their grant needs RCR Training.
• When needed, Research Integrity will request assistance from the PI to help push along all those that remain delinquent in completing the RCR Training.
• RCR Exceptions: If the PI believes there is an individual that does not meet the RCR requirements they may request to have the RCR requirement removed. Requests must be emailed to the RCR Coordinator and please provide a reason for the exception (i.e: the individual is not conducting or participating in the research, conference, travel, workshop, or symposium specific award).
• UVM RCR Coordinator, Nicole Schwartz or Brian Prindle (rcr@uvm.edu).

A. CITI Login for those who are already registered for a UVM CITI Account

1. Access the CITI Login. 
2. Choose "Log in through my Institution". Scroll down and click on "University of Vermont".
3. Login using your UVM NetID and Password (if necessary).
4. From the Main Menu, select "University of Vermont Courses.
5. Select "Add a Course."
6. Choose "Responsible Conduct of Research (RCR) - Basic."
7. Start course and complete the Required modules.
8. Users may save their work and return to CITI at any time to complete the training.
9. When you return to CITI, always login thru "Log in through my Institution". This avoids creating multiple CITI accounts and having to restart training.

NOTE: DO NOT CHOOSE "Responsible Conduct of Research - Refresher". This course will NOT satisfy the requirement.

B. Registration Instructions for those who do not have a UVM CITI Account

1. Access the CITI Login. 
2. Click on "Log In" located at the top right of the CITI page.
3. Click "Log In Through My Institution". Scroll down and click on "University of Vermont".
4. Enter your UVM Net ID and password to sign in.
5. If you have not associated your UVM account with CITI, you will be prompted to choose whether you already have a CITI Program account or if you do not have a CITI Program account.
6. If you have a CITI Account, choose the first option and follow the instructions to link your UVM account with your CITI Account.
7. If you do not have a CITI account, choose the second option and select "Click here to create a new CITI Program account." If you do not receive these prompts, then proceed to step 8.
8. From the Main Menu, select "University of Vermont Courses."
9. Select "Add a Course".
10. Choose "Responsible Conduct of Research (RCR) - Basic."
11. Start course and complete the Required modules.
12. Users may save their work and return to CITI at anytime to complete the training.
13. When you return always use the command "Log in through my Institution". This avoids creating multiple CITI accounts and having to restart training.

NOTE: DO NOT CHOOSE "Responsible Conduct of Research - Refresher". This course will NOT satisfy the requirement.

NSF Proposal and Award Policies and Procedures Guide (PAPPG), NSF 23-1, dated January 30, 2023.

The National Institute for Food and Agriculture (NIFA) requires program directors, faculty, undergraduate students, graduate students, postdoctoral researchers, and any staff participating in a NIFA research project, including capacity (formula) funds receive appropriate training and oversight in the responsible and ethical conduct of research (RCR) and that documentation of such training is maintained and available upon request.

The RCR Training requirement can be found on page 9 of the NIFA Grant Agreement Terms and Conditions (PDF).

All faculty, principal investigators, co-principal investigators, graduate students, undergraduate students, postdoctoral researchers and staff who are participating in a NIFA research project and paid (salary or stipend) from a NIFA grant awarded to UVM directly or as a subrecipient are required to complete the Responsible Conduct of Research (RCR) - Basic Training Course offered on-line through the CITI Program. The CITI Basic RCR Course covers all essential RCR topics.

• RCR Training should be completed within the first 3 months on the project.
• RCR Training is completed once.
• RCR Training satisfies both the NIFA and NSF RCR Training requirement.
• Research Integrity will notify individuals by email and provide CITI login instructions.
• RCR email reminders will be sent monthly to only those that have not completed RCR Training.
• Once RCR Training is complete the email remiders will stop.
• The PI of the NIFA award will be copied on all emails, keeping them informed about who on their grant needs RCR training.
• When needed, Research Integrity will request assistance from the PI to help push along all those that remain delinquent in completing the RCR training.
• RCR Exceptions: If the PI believes there is an individual that does not meet the RCR requirements they may request to have the RCR requirement removed. Requests must be emailed to the RCR Coordinator and please provide a reason for the exception (i.e: the individual is not conducting or participating in the research, conference, travel, workshop, or symposium specific award).
• UVM RCR Coordinator, Nicole Schwartz or Brian Prindle (rcr@uvm.edu).

• RCR email reminders will be sent monthly to only those who have not completed RCR Training.
• Once RCR Training is complete the email remiders will stop.
• The PI of the NIFA award will be copied on all emails, keeping them informed about who on their grant needs RCR Training.
• When needed, Research Integrity will request assistance from the PI to help push along all those that remain delinquent in completing the RCR Training.
• RCR Exceptions: If the PI believes there is an individual that does not meet the RCR requirements they may request to have the RCR requirement removed. Requests must be emailed to the RCR Coordinator and please provide a reason for the exception (i.e: the individual is not conducting or participating in the research, conference, travel, workshop, or symposium specific award).
• UVM RCR Coordinator, Nicole Schwartz or Brian Prindle (rcr@uvm.edu).

A. CITI Login for those who are already registered for a UVM CITI Account

1. Access the CITI Login.
2. Choose "Log in through my Institution". Scroll down and click on "University of Vermont".
3. Login using your UVM NetID and Password (if necessary).
4. From the Main Menu, select "University of Vermont Courses.
5. Select "Add a Course."
6. Choose "Responsible Conduct of Research (RCR) - Basic."
7. Start course and complete the Required modules.
8. Users may save their work and return to CITI at any time to complete the training.
9. When you return to CITI, always login thru "Log in through my Institution". This avoids creating multiple CITI accounts and having to restart training.

NOTE: DO NOT CHOOSE "Responsible Conduct of Research - Refresher". This course will NOT satisfy the requirement.

B. Registration Instructions for those who do not have a UVM CITI Account

1. Access the CITI Login.
2. Click on "Log In" located at the top right of the CITI page.
3. Click "Log In Through My Institution". Scroll down and click on "University of Vermont".
4. Enter your UVM Net ID and password to sign in.
5. If you have not associated your UVM account with CITI, you will be prompted to choose whether you already have a CITI Program account or if you do not have a CITI Program account.
6. If you have a CITI Account, choose the first option and follow the instructions to link your UVM account with your CITI Account.
7. If you do not have a CITI account, choose the second option and select "Click here to create a new CITI Program account." If you do not receive these prompts, then proceed to step 8.
8. From the Main Menu, select "University of Vermont Courses."
9. Select "Add a Course".
10. Choose "Responsible Conduct of Research (RCR) - Basic."
11. Start course and complete the Required modules.
12. Users may save their work and return to CITI at anytime to complete the training.
13. When you return always use the command "Log in through my Institution". This avoids creating multiple CITI accounts and having to restart training.

NOTE: DO NOT CHOOSE "Responsible Conduct of Research - Refresher". This course will NOT satisfy the requirement.

NIH requires all trainees, fellows, participants, and scholars receiving support through any NIH training, career development award (individual or institutional), research education grant, and dissertation research grant receive training in Responsible Conduct of Research.

This RCR Training requirement applies to the following programs: D43, D71, F05, F30, F31, F32, F33, F34, F37, F38, K01, K02, K05, K07, K08, K12, K18, K22, K23, K24, K25, K26, K30, K99/R00, KL1, KL2, R25, R36, T15, T32, T34, T35, T36, T37, T90/R90, TL1, TU2, and U2R.

• NIH Guide: Instructions for RCR

• Principal Investigators must submit an RCR Training Plan in the proposal submission that meets the RCR Training expectations of the NIH.
• The Principal Investigator is responsible for maintaining RCR training records to document that all NIH supported trainees, fellows, and scholars received the required instruction.
• RCR Training Plans must include significant face-to-face interaction and participation
• The following topics have been incorporated into most acceptable RCR Training Plans: 
  • Data Acquisition, Management, Sharing and Ownership
  • Conflict of Interest and Commitment (PDF)
  • Human Subjects
  • Animal Welfare
  • Research Misconduct
  • Publication Practices and Responsible Authorship
  • Mentor / Trainee Responsibilities
  • Peer Review
  • Collaborative Research

Common courses that area good source of RCR Training and can be included in a NIH RCR Training Plan:

• UVM course, NSCI 327 - Responsible Conduct in Biomedical Research (Course Description: Topics in Scientific Integrity surrounding responsible conduct and practices in biomedical research. Prerequisites: Advanced Graduate students, postdoctoral fellows and assistant professors in the biological or biomedical sciences) is a common element of most UVM NIH RCR Training Plans.
• The Collaborative Institutional Training Initiative (CITI) on-line “Responsible Conduct of Research – Basic Course” is also a good source of RCR Training and can be included in a NIH RCR Training Plan.

UVM's Financial Conflict of Interest (FCOI) in Sponsored Research Policy (PDF) has been designed to ensure complaince with federal regulation and implements a process to review and manage disclosed Significant Financial Interest (SFI) that have the potential to compromise the objectivity of the research being conducted.

The FCOI Policy requires Investigators to do the following;

1. Complete Disclosures. All Investigators thru the UVMClick - COI system must disclose whether or not they hold any Significant Financial Interest (PDF). Disclosures are made annually, updated as approriate, and updated at time of a new sponsored project award. The UVMClick – COI system will automatically remind Investigators when to log in and complete their annual certification/disclosure. 
2. Complete FCOI Training. FCOI Training is required every 4 years. Navigate to CITI Program, our online source for FCOI Training. FCOI Training reminders will come directly from CITI.

Who

1. Investigators must disclose whether or not a Significant Financial Interest (PDF) is held by themselves, their spouses, or their dependent children related to their institutional responsibilities when funded research is proposed, annually thereafter, and make an updated disclosure when any new Significant Financial Interest arises.
2. “Investigator” is defined as the Principal Investigator (PI), Project Director (PD) or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research proposed to, or funded by, external sponsors, under grants, contracts, cooperative agreements, or other awards for research.

When

1. Annual certification/disclosures are required by all Investigators using the UVMClick – FCOI system.
2. UVMClick will automatically remind Investigators when they must log in and complete their annual certification/disclosure.
3. The annual certification/disclosure satisfies the requirement that a disclosure is made at time of proposal submission.
4. If an annual certification/disclosure is not present at the time of proposal submission, SPA will trigger an event that directs the Investigator to log in and complete disclosure.

If you qualify as an Investigator, you are required to make disclose whether or not you hold a significant financial interest (PDF).

It is not the responsibility of the Investigator to determine whether or not there is a conflict.

It is the responsibility of the research compliance officer, and ultimately the Financial Conflict of Interest Committee, to determine whether there is a conflict with any ongoing research.

As a reminder:

1. Significant Financial Interest (PDF) means a financial interest that could directly and significantly, affect the design, conduct, or reporting of externally funded research. Investigators using UVMClick – FCOI will either certify no SFI or disclose SFI.
2. Financial Conflict of Interest (FCOI) means a Significant Financial Interest (SFI) that could directly and significantly, affect the design, conduct, or reporting of externally funded research. All disclosed SFI will be reviewed at time of award by our Research Compliance Officer or the FCOI Committee to determine if the disclosed SFI is an FCOI.

1. At time of award acceptance, for those disclosures that indicate a Significant Financial Interest (SFI), SPA will trigger a Research Certification update.
2. All research certifications where an SFI exists will be reviewed by our Research Compliance Officer or the FCOI Committee to determine if the SFI is a Financial Conflict of Interest (FCOI).
3. Where an FCOI exists, award funds may not be released into PeopleSoft financials until the FCOI is either eliminated or managed with a management plan.

Training completion dates.

1. UVM FCOI Policy requires Investigators to complete FCOI training every 4-years.
2. CITI is our online source for FCOI Training.
3. Login to CITI through the “Login Through My Institution” portal, selecting the University of Vermont.
4. FCOI Training reminders are delivered directly from CITI. (30, 7, and 1 day before training expiration and 1, 7, 30 days after expiration) That's 6 reminders!
5. Award funds may not be released into PeopleSoft financials until all Investigators are FCOI trained.

Please Note: You will not be able to complete your disclosure if your FCOI training has expired. Once you complete the FCOI training, it takes an overnight refresh, for your COI Training complete cert to link to UVMClick disclosure, once linked, you will be able to complete and submit your disclosure.

Already have a UVM-affiliated CITI account?

1. Always login to CITI through the “Log In Through My Institution” portal and select the University of Vermont.
2. To add the FCOI Training Course, select “View Courses”
3. Scroll to “Learner Tools for University of Vermont”
4. Select “Add a Course”
5. Select "Conflicts of Interest” and complete the course.

Create a UVM-affiliated CITI account:

Registration Instructions for those who do not have a UVM CITI Account.

1. Open your browser and go to CITI Program – Login.
2. Click on "Login" which is located at the top right of the CITI page.
3. Then, click "Login Through My Institution" to view registered organizations.
4. From the drop-down menu, click on "University of Vermont".
5. Sign in with your UVM Net ID and password.
6. You will be prompted to affiliate your CITI account with UVM.
7. If you have an existing CITI account, choose first option and follow the instructions to link your UVM account.
8. Otherwise, choose second option and select "Click here to create a new CITI Program Account."
9. If you do not receive these prompts, then proceed to step 5.
10. To add the FCOI Training Course, select “View Courses”
11. Scroll to “Learner Tools for University of Vermont”
12. Select “Add a Course”
13. Select "Conflicts of Interest” and complete the course.

Preferred Email: Please check to ensure the email registered with CITI is your FirstName.LastName@uvm.edu. If not, please update thru your account settings.

• National Science Foundation Research (PDF)
• Public Health Service Research (PDF)
• All Other Sponsored Research (PDF)

1. NIH Financial Conflict of Interest
2. NSF Financial Conflict of  Interest
3. NASA Financial Conflict of Interest (PDF)
4. Energy Financial Conflict of Interest (PDF)

The FCOI Policy is different from the Conflicts of Interest and Conflicts of Commitment Policy, which applies to all UVM employees, including staff, whether or not they are engaged in sponsored research.

Both FCOI and COI disclosures are made under the same disclosure form thru UVMClick - COI.

Export Controls are a set of laws and regulations that regulate the distribution of export controlled technology, equipment, software, information, or services to a foreign person or to a foreign country.

• U.S. Export Administration Regulations can be found at: Export Administration Regulations (EAR)
• The Commerce Control List can be found at: CCL List
• U.S. International Traffic in Arms Regulations can be found at: International Traffic in Arms Regulations

See which U.S. Agency oversees What Export Control Regulation (EAR, ITAR) (PDF)

All University of Vermont faculty, staff, students, trainees, visitors, and other persons retained by or working at or for UVM involved in research and scholarly activities or activities are subject to the UVM Export Control Policy (PDF).

The United States, like most countries, has laws which control the export of certain strategic tangible and non-tangible items.

• Export control violations can result in civil and criminal penalties which may apply to an individual and/or the institution up to $1 million and/or 20 years of imprisonment, per violation.
• Administrative Penalties include loss of export privileges or suspension and debarment from government contracting.

At time of award, SPA Award Acceptance Officers will review awards for identifiers that would have the project be subject to export control regulations.

• SPA Award Acceptance Officer Export Control Process Document/Checklist (PDF)

All projects identified by SPA with possible export control concerns are referred to the Office of Research Integrity for a final determination.

If a project is deemed subject to export control regulations, a Technology Control Plan (TCP) and Training of all project staff must be completed prior to the release of the awarded funds.

If UVM’s Research Compliance Officer or Executive Director determines that the sponsored project activity is subject to any of the export control regulations, establishment of a Technology Control Plan (TCP) or other certification document will need to be generated.

The Technology Control Plan details the export control classification, restriction on release of information, physical and information security protocols, project personnel requirements and other requirements to ensure all parties understand their obligations.

Fundamental Research Exemption Matrix (PDF)

There is one exception that benefits researchers who are conducting research with the intent of publishing and sharing their results with other researchers. It is called the Fundamental Research Exemption.

To qualify for a Fundamental Research exemption, the following needs to be evident in the award:

There should be no publication restrictions. A sponsor “review and comment” (not approval) of a publication is not considered a restriction.

• There should be no foreign person restrictions.
• The scope of research work should be basic or applied.
• The work must be done at a U.S. accredited institution of higher learning in the U.S.
• There is no specific national security controls on the research or results.

1. Export Control Compliance Training is available to UVM personnel through the Collaborative Institutional Training Initiative (CITI) Program.
   • Introduction to Export Compliance (ID:16800)
   • Export Compliance for Researchers: Part I (ID:16801)
   • Export Compliance for Researchers: Part II (ID:16802)
2. The Office of Research Integrity can provide a brief overview of Export Control Regulations and UVMs sponsored project review process and procedures to individuals or groups interested in obtaining an introduction to the basics of export control.
   • To schedule a presentation of this session at your next departmental or college meeting, please contact Victoria Jones, LL.M., Research Compliance Officer, at Victoria.Jones.1@uvm.edu or 656-1329.
3. The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) provides seminars on export controls related to commodities covered by the Export Administration Regulations. A schedule of export control seminars available  through BIS is located at the following BIS Online Training Room.
   • For more information on the courses, including a description of the available sessions, visit the BIS Export Regulations Training Courses.

Visual Compliance is a web-based export control management tool that is useful for conducting the following export control compliance functions:

• Restricted parties screening;
• Locating Federal Regulations on export controls;
• Searching the ECCN and USML; and,
• Assisting in license determinations.

Research Integrity has a license to use Visual Compliance to assist in export controls compliance at the University of Vermont.

To schedule a Visual Compliance review contact Victoria Jones, LL.M., Research Compliance Officer, at Victoria.Jones.1@uvm.edu or 656-1329.

If you find yourself about to engage in a research activity related to export-controlled (EAR, ITAR) items please contact Victoria Jones, LL.M., Research Compliance Officer, at Victoria.Jones.1@uvm.edu or 802-656-1329.

What is Controlled Unclassified Information (CUI): Government created or owned UNCLASSIFIED information that by law, regulation, or Government-wide policy must be safeguarded from unauthorized disclosure.

Executive Order 13556 (PDF)

As required by the federal government, CUI can only be stored and processed on IT systems that have been risk assessed to comply with NIST SP 800-171 standards. Therefore, UVM Investigators who will engage in a sponsored project that will require the use of CUI can only do so within an approved CUI environment.

CUI environments must be approved by UVM’s Chief Information Security Officer, Scott.Carbee@uvm.edu.

Investigators, should not engage, accept, or receive CUI for any reason or purpose until an appropriate Information Security Plan (ISP) is in place and approved by the UVM Chief Information Security Officer.

Where SPA identifies a CUI Project, SPA will connect the Principal Investigator to the UVM Chief Information Security Officer who will then work with the research team to develop an appropriate Information Security Plan (ISP), which safeguards the CUI and controls unauthorized dissemination.

For any reason a SPA project is not initially identified as using CUI in the work, it is the responsibility of the Investigator to initiate an Information Security Plan by contacting our Research Compliance Officer, Victoria Jones and our Chief Information Security Officer, Scott Carbee.

For more Information, see:

• University Operating Procedure (UOP): Controlled Unclassified Information (PDF)
• SPA Procedures: Review for Controlled Unclassified Information (CUI) at time of Proposal and at time of Contracting (PDF)

UVM complies with the US Dept of ED section 117 and NSF foreign reporting requirements.

The Office of Research Administration and Integrity is responsible for the data collection activities and reporting. The following Departments are contacted twice a year for the necessary data to comply with Section 117 and once a year to comply with the NSF requirements.

• Sponsored Project Administration
• UVM Foundation
• UVM Innovation

Section 117 of the Higher Education Act, requires U.S. institutions of higher education to report gifts and contracts with a foreign source that, considered alone or in combination with all other gifts and contracts from the same foreign source are valued at $250,000 or more in a calendar year.

• Reports are submitted twice a year.
• January 31 (covering the previous July 1-December 31 period)
• July 31 (covering the previous January 1-June 30 period).
• Reports are submitted through a secure ED Section 117 Reporting System.
• ED Guidance “Reminder to Report Ownership/Control by, and Contracts/Gifts from, Foreign Sources”.
• Appendix A outlines required reporting element (PDF)
• Appendix B provides responses to public comments about the requirements (PDF).

See the NSF Final Rule for details.