Crafting the RCR Section in Application & Progress Report
Let’s talk about Training in the Responsible Conduct of Research (RCR) – you know, that one-page, required piece of an NIH grant application that could use a little attention. NIH released new guidance (effective September 25, 2022) that does not substantially change prior guidelines, but serves as a good prompt to revisit the requirement.
While RCR is not a scored review element, it is required and will be evaluated as “acceptable” or “unacceptable.” Grants receiving an overall fundable score will need to amend an “unacceptable” plan before a grant is fully funded. Likewise, continuation funding can be withheld if an acceptable RCR update is not included in your annual progress report.
So…what is the expectation and how can you get it right?
NIH dictates five instructional components. For F-awards, especially, outlining your RCR plan in this same format is wise. You’ll make the reviewers’ job very easy if they can see at a glance that all components are addressed. Think of this list as a checklist the next time you prepare an RCR plan.
- Format: Will the experience be face-to-face? Coursework? Discussion groups? Online or video conference instruction is acceptable, but cannot be the sole format. Think about all the things you are already doing that can count as learning or teaching RCR.
- Subject Matter: Early career stages need a plan for broad coverage of NIH-recommended subject areas (think: ethics course during graduate school or day-long workshop during faculty/fellowship onboarding). Later-stage researchers can begin to concentrate on areas most closely related to scientific expertise. NIH’s current areas include:
- Conflict of interest & conflict of commitment (time, effort)
- Policies regarding human subjects, vertebrate animals, lab safety
- Mentor/mentee responsibilities & relationships
- Safe research environments (free from discrimination, harassment)
- Collaborative research (domestic, international, industry)
- Peer review (confidentiality, security)
- Data acquisition & analysis; lab tools (including digital images); recordkeeping (including e-notebooks)
- Secure & ethical data use (confidentiality, management, sharing, ownership)
- Research misconduct
- Responsible authorship & publication
- Scientist as a responsible member of society; contemporary ethical issues; societal impact of research
- Faculty Participation: Which faculty are involved in instruction? Especially name your mentor(s) or program faculty who lead instruction and specify the roles they will play. Are you providing instruction to others?
- Duration of Instruction: Describe the total number of contact hours of instruction, taking into consideration the duration of your grant. Does your institution/department have a required number of hours each year? Likely, you’ll be expected to meet or exceed the NIH recommendation of eight contact hours (minimum) for a single training plan.
- Frequency & Timing of Instruction: Instruction must occur during each career stage (translation: as a graduate student, again as a postdoc, again as an assistant professor) and at least once every four years. Describe any prior training during your current career stage, including the dates instruction was last completed. Consider that training may need to be repeated during the proposed grant period if four years elapses.
Career Stage Considerations
As a K-award applicant, you’ll have more leniency in formatting this section due to the advanced career stage. You’ll want to start by describing your most recent, prior RCR training.
- Did you already complete a broad RCR training course in the last four years? Perhaps your home institution offers one for every new research faculty hire. If so, describe that prior instruction, including the date instruction was completed.
- Was your prior instruction during a prior career stage (e.g., as a postdoc)? If so, additionally describe the initial training you will receive in this new career stage.
Second, propose plans to receive instruction and/or provide instruction (e.g., to participate as a course lecturer). Consider the Frequency & Timing section, above: if your grant is for five years, you will need to plan to refresh your training at least once to meet the “every four years” requirement. Propose activities that will enhance your understanding of ethical issues related to your specific research activities and the societal impact of that research. Propose activities that actually interest you – independent scholarly activities are permitted – or activities that are already part of your academic duties (e.g., writing case studies, moderating graduate courses, attending seminars, discussions with mentees). Also describe the role(s) your mentors will play in your instruction.
For Annual Progress Reports
Ok, you got the grant. Yay! Each year, you’ll submit a progress report, which needs to include a description of your RCR training (formal and informal) over the past year. The intent is for RCR to be a continual and integrated part of research and career development. Keep in mind that next year’s grant dollars can be withheld if the RCR section of the progress report is not complete.
- Formal Instruction: Did you complete the annual IACUC/IRB training this year? Did you complete the full RCR course offered by your program or institution this year (because it’s been 4 years, or you changed career levels, or the course was previously unavailable)? Did you act as an instructor or moderator in a formal RCR course? Be sure to include completion dates and align your description with the five components above.
- Informal Instruction: How have you stayed connected to good research practice this past year? Conversations with your mentor about your research? Training a graduate student in your lab? Journal club conversations about cases of misconduct? Writing RCR case studies? Attended or presented seminars on RCR topics? In the case of seminars, consider listing the date, title, and presenter.
- Individualization: Particularly for K-awardees, ongoing RCR activities can be uniquely tailored to your career stage or area of scientific expertise. This could include creating an independent study, publishing case studies, developing course content. In your description, include the role your mentor(s) play in your plans.
All the tech speak lives in the NIH Grants Policy Statement
- F Fellowships: NIH Grants Policy Statement, Section 184.108.40.206: Responsible Conduct of Research
- K Awards: NIH Grants Policy Statement, Section 220.127.116.11: Training in the Responsible Conduct of Research