Effective as of 01.04.2009
These procedures provide additional administrative guidance to assure compliance with The Washington University NSF COMPETES Compliance Plan.
The effectiveness and appropriateness of these procedures will be evaluated regularly and will be improved, expanded, or modified as needed. All updates will be communicated to the Washington University research community via the Research News listserv.
The WashU NSF COMPETES Compliance Plan consists of two components:
1. One-time completion of the WashU Program for Ethical and Responsible Conduct in Science and Scholarship (PERCSS) Core Curriculum, which consists of eight online learning modules. All qualifying individuals currently being paid by NSF sponsored projects as of January 4, 2010 are required to complete the PERCSS Core Curriculum within ninety (90) days. All newly appointed qualifying individuals to be paid by NSF sponsored projects as of January 4, 2010 are required to complete the PERCSS Core Curriculum within thirty (30) days of being paid from the NSF award.
2. Continuing education consisting of at least one face‐to‐face education session each project year.
All qualifying individuals EXCEPT undergraduate students paid from the NSF project for less than three (3) consecutive months are required to meet the continuing education requirement of at least one face-to-face education session each project year. The project year is determined by the award’s anniversary date.
For more specific information, access the WashU NSF COMPETES Compliance Plan.
Process for Compliance
The responsibility for assuring compliance is a joint effort between principal investigators, schools, departments, and programs, the Offices of Sponsored Research, the undergraduate student, graduate student or postdoctoral researcher, and the institution. Outlined below are the procedures and roles and responsibilities each of these entities must follow.
The Principal Investigator (PI) is responsible for assuring compliance with this Compliance Plan for all qualifying individuals supported by NSF funds as described in the Washington University RCR Compliance Plan. This includes appropriate identification of the eligible individuals, providing time to complete the PERCSS modules and encouraging, and permitting attendance at continuing education sessions.
School, Department, or Program
PERCSS Core Curriculum
All qualifying individuals must complete the PERCSS Core Curriculum within thirty (30) days of being paid from the NSF award. To facilitate completion of the PERCSS Core Curriculum, the appropriate school, department, or program administrator must:
- Identify and enter qualifying individuals into HRMS and provide each individual with his/her employee ID number (this is required to access the PERCSS Core Curriculum).
- Inform each qualifying individual of his/her need to complete the PERCSS Core Curriculum and provide the date by which he/she is expected to comply.
- Direct the individual to the Learn@Work system to access the PERCSS Core Curriculum training.
Continuing RCR Education
All qualifying individuals EXCEPT undergraduate students paid from the NSF project for less than three (3) consecutive months are required to meet the continuing education requirement of at least one face-to-face education session. This is a recurring requirement that must be completed once each project year that the individual is paid from the NSF project.
Continuing RCR education must meet certain criteria. For more information, visit the Continuing RCR Education Requirement webpage. It is the responsibility of schools, departments, and programs in receipt of NSF funds to provide programming or referrals to appropriate programming. To facilitate completion of the continuing RCR education requirement, the appropriate school, department, or program administrator must:
- Provide face-to-face programming or referrals to appropriate programming that is discipline and career-level appropriate.
- Collect documentation and maintain records of educational content and proof of attendance for each session attended by a qualifying individual AND submit attendance records within 30 days of each session.
- For instructions and to submit records, visit Continuing RCR Education Submission.
Schools, departments, and programs are required to assure compliance for all NSF research projects they administer. The administration must:
1. Verify that qualifying individuals have complied with education requirements within the applicable timeline for completion; and
2. Implement necessary internal procedures to assure that issues of noncompliance are identified and resolved.
Washington University tracks completion of these requirements via the Compliance Module. Visit https://learnatwork.wustl.edu/training to find information on accessing training records under “Administrator User Guides.”
Office of Sponsored Research Services
The Office of Sponsored Research Services (OSRS) is responsible for providing institutional assurance of compliance with the Compliance Plan to all applicable sponsors. OSRS will also monitor compliance with this Compliance Plan in the following ways:
- At the time a NSF proposal is submitted, OSRS will certify that the institution has a plan to comply with the NSF regulations governing RCR education.
- At the time the Notice of Award is distributed, OSRS will provide a reminder to the Principal Investigator and Department Administrator that they must comply with the WUSTL NSF COMPETES Compliance Plan.
- OSRS will monitor compliance with the PERCSS Core Curriculum requirement on a quarterly basis. At this time, OSRS will review the Compliance Module to determine whether all qualifying individuals have completed the PERCSS Core Curriculum within the appropriate timeframe. Departments will be notified of issues and asked to contact the all non-compliant individuals to comply within ten (10) days.
- OSRS will monitor compliance with the continuing RCR education requirement at each annual anniversary of the award. At this time, OSRS will review the Compliance Module to determine whether all qualifying individuals have completed the Continuing RCR Education Requirement within the appropriate time frame.
- OSRS will record instances of noncompliance and forward such issues to the VCR as appropriate.
University Compliance Office
The university will add this requirement to its audit plan for schools, departments, and compliance offices.
Issues of non-compliance that are identified through ongoing monitoring activities will be forwarded to the Vice Chancellor for Research who is responsible for imposing sanctions.
Failure to gain compliance within the specified timeline and/or circumstances of repeated or egregious noncompliance may result in the restriction of access to all project funds from the noncompliant NSF project(s) until compliance is obtained.
If you would like to submit a question regarding NSF COMPETES Compliance at WUSTL, please email email@example.com. We will respond to your email within 3-5 business days.