Exactly who among those working on my project must complete RCR?

• The policy language requires “Principal Investigators and key personnel participating in sponsored projects, including staff, postdoctoral fellows, and graduate and undergraduate students” to complete CITI online RCR education
  1. This means, anyone named in a proposal or reportable as key personnel (in an annual grant report) should meet the threshold for RCR education
  2. However, Exempt from CITI RCR would be:
     • Students in purely administrative roles, defined as those who have no role in proposing, performing, or reviewing research, or in reporting research results.
     • Administrative staff who have no contact with the research
     • PIs should make these determinations.

Why are students required to do the online component?

• The policy mandate follows on NSF’s aim: to make the next generation of researchers aware of all aspects of research ethics.
• A large percentage of concerns brought to ORSP involves students. To the extent that education is preventive, the online education component should help students avoid these concerns and focus on their work instead.

Isn’t this excessively time-consuming – for any benefit?

• URB viewed this education as ultimately saving time, effort, and, in some cases, money. A few examples:
  1. All of our research misconduct cases arose out of ignorance or carelessness, and, all cases had enormous time and emotional costs - for all participants. UM has been lucky so far: many US cases cost more than $1M to resolve [one cost $38M].
  2. Authorship disputes result in ill will at best and fractured relationships (often between students and mentors) at worst.
  3. Collaborations fail for lack of simple planning. These waste time and both UM and external funds.
  4. PIs starting up companies spend time and money getting established – only to learn later that they violate state conflict of interest laws and UM policy.
  5. Students’ mentors are gone so often or spread so thin that student research and scholarly projects get little guidance and cost students more years in school.

I’ve previously done the CITI online IRB education; does that cover this RCR requirement?

• No. CITI provides three online education programs with zero overlap among them: human subjects research (IRB), animal research (IACUC), and responsible conduct of research (RCR).

I found many typographical and grammatical errors in the CITI RCR. Why isn’t this material fully proofed?

• CITI programs are constantly evolving and improving in both content and form (and CITI has limited staff).