Why am I getting a letter about Responsible Conduct of Research training?
You will receive a letter about Responsible Conduct of Research training when your salary becomes supported by a grant from the National Science Foundation (NSF). NSF requires that all undergraduate students, graduate students and postdoctoral associates and fellows supported on its awards complete Responsible Conduct of Research Training.
Who must complete Responsible Conduct of Research training?
The NSF expects institutions to be able to verify that those students (undergraduates and graduates) and postdoctoral researchers who receive NSF funds (support from salary and/or stipends to conduct research on NSF grants) will obtain RCR training. However, NSF anticipates that institutions will develop their RCR training programs in a manner that helps prepare the next generation of researchers, including the consideration of risks or other factors associated with student and postdoctoral researcher participation in research. For more information go to http://osp.mit.edu/compliance/responsible-conduct-research
Do undergraduates, graduate students and postdoctoral researchers have to receive RCR training before being identified on a proposal to NSF?
No. It is not required that the training be completed at that time. The MIT plan for training requires that training be completed within 60 days of their salary being charged to the account. OSP strongly recommends that the training be completed within 30 days.
How do I know when an award requires MIT execution?
Some proposals result in unilateral awards; based on the proposal and through budget revisions, the sponsor issues an award document. In these cases, a formal acceptance of the award signature by MIT is not required because our expenditure of funds demonstrates our acceptance of the award terms and conditions. These are known as unilateral awards. NSF and NIH grant awards are examples of such unilateral awards.
When a sponsor requires that an MIT-authorized official sign to accept the award terms and conditions, the award is called a bilateral award. Typically, federal contracts and most foundation and industry awards are bilateral.
What is considered allowable cost sharing on NSF awards?
Since 2009, the NSF has prohibited the inclusion of voluntary cost sharing in proposals. Cost sharing may only be included in NSF proposals where it is specified as mandatory for that particular program (such as the Major Research Instrumentation opportunities). As of 2014, the NSF has clarified that unfunded personnel may not be listed in the budget justification, and that only federally negotiated indirect cost rates will be accepted. Offering non-specific effort or a reduced indirect cost rate in the budget justification is considered a violation of the cost sharing policy.
My NSF award references 42 US Code 1869a and 1869b; what does this law mean?
This code is most often found in awards with a major educational component, like the NSF CAREER awards. Under this law, the National Science Foundation must include special terms in any project that is anticipated to result in pre-college curriculum development. The terms require that the awardee (MIT) obtain prior written approval from the school board (or equivalent) prior to involving pre-college students in your project. Additionally, all instructional materials developed must be made available within the school district for inspection by parents and guardians of children involved. If your project includes any K-12 curriculum development, be sure to share copies of all school board written approvals with OSP.
Is this certification also required for NIH, DOD and other sponsors? Or is it just for proposals submitted to NSF?
Section 7009 of the America COMPETES Act was directed solely at the National Science Foundation, and the foundations implementation therefore applies to proposals submitted or due to NSF on or after January 4, 2010. NSF is aware that other agencies may have other RCR training requirements.
Can I use the Fund Fee (non-research indirect cost rate) on a NSF proposal or award?
No. As of 2013, the NSF has specified that only federally negotiated indirect cost rates are allowable on NSF awards. MIT does not have a federally negotiated F&A rate for non-research activities. However, federal regulations allow us to charge a de minimis F&A rate of 10% MTDC on non-research activity funded by Federal awards, provided we do so consistently. This is the rate that should be proposed and will be charged. DLCs are not required to fund underrecoveries of fund overhead associated with awards that receive the de minimis rate.