Responsible Conduct of Research


Created 01/04/2009
Revised 07/31/2023


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 Research News.


See the NSF COMPETES Compliance Plan for training requirements.

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.

Principal Investigator

The Principal Investigator (PI) is responsible for assuring compliance with this Compliance Plan for all 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 required training, and encouraging and permitting attendance at continuing education sessions.

School, Department, or Program

Learn@Work Training Courses

All faculty, staff senior personnel, students, postdocs, and other trainees must complete their required training via Learn@Work within thirty (30) days of being paid from the NSF award. To facilitate completion of the RCR trainings in Learn@Work, the appropriate school, department, or program administrator must:

  1. Inform individuals of their need to complete training, and provide the date by which they are expected to comply.
  2. Direct individuals to Learn@Work to access their required training:
    • Faculty & Staff listed as senior personnel: Responsible & Ethical Conduct of Research
      • Faculty: assigned automatically
      • Staff: all staff paid by NSF are assigned and encouraged to complete training, however only senior personnel are required to do so.
    • Students, Postdocs, and Other trainees: PERCSS Core Curriculum (assigned automatically)

Continuing RCR Education

The NSF does not require faculty and senior personnel to complete continuing RCR education.

All students, postdocs, and other trainees (EXCLUDING undergraduate students paid from the NSF project for less than three 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:

  1. Provide face-to-face programming or referrals to appropriate programming that is discipline and career-level appropriate.
  2. Collect documentation and maintain records of educational content and proof of attendance for each session attended by students, postdocs, and other trainees.
    Optional: To store training records centrally via Learn@Work, submit attendance records within 30 days of each session to Research Education & Information. Visit Continuing RCR Education Submission​ for instructions.


Schools, departments, and programs are required to assure compliance for all NSF research projects they administer. The administration must:

  1. Verify 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.

This PERCSS Core Curriculum and the Responsible and Ethical Conduct of Research training records can be found via the WU Compliance Training for Researchers Learn@Work report. Instructions on running or scheduling this report are available on the Trainings for Researchers page. This report will capture faculty, staff, students, and postdocs automatically assigned RCR training. Because RCR training cannot be automatically assigned to staff listed as senior personnel, departments are encouraged to create a monitoring plan to ensure compliance for this group.

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 in the following ways:

  1. 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.
  2. OSRS will monitor compliance with web-based RCR training requirements in Learn@Work on a quarterly basis. At this time, OSRS will review whether individuals have completed their applicable training 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.
  3. 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.


Contact Research Education & Information with any questions regarding the NSF COMPETES Procedures.