Responsible Conduct of Research

NSF COMPETES Compliance Plan

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


Congress passed Public Law 110-69, The America COMPETES Act on August 9, 2007. This law mandates that the National Science Foundation (NSF) require institutions in receipt of NSF funds provide appropriate training and oversight in the responsible and ethical conduct of research for undergraduate students, graduate students and postdoctoral researchers who are supported by NSF to conduct research. Access to this law is available via NSF’s Implementation of Section 7009 of the America COMPETES Act.

In 2022, the NSF expanded the RCR requirement to also include “faculty, and other senior personnel,” to the requirements, effective for new proposals submitted or due on or after July 31, 2023.


Individuals paid by NSF funds (salary, stipends, etc.) are required to complete one of the following trainings based on their role:


One-time completion of the Responsible and Ethical Conduct of Research online training

Staff listed as senior personnel on an NSF proposal

One-time completion of the Responsible and Ethical Conduct of Research online training

Students, postdocs, and other trainees

  1. One-time completion of the Program for Ethical and Responsible Conduct in Science and Scholarship (PERCSS) Core Curriculum, which consists of eight online learning modules.
  2. Continuing education consisting of at least one face‐to‐face education session each project year.
    Exception: Face-to-face training not required for undergraduate students paid from an NSF project for less than three consecutive months.

All Washington University faculty, staff listed as senior personnel, undergraduate students, graduate students, and postdoctoral fellows paid by salary or stipend from NSF sponsored projects must complete applicable RCR training (listed above) within thirty (30) days of being paid from the NSF award.

Face-to-face education must be discipline and career‐level appropriate. It is the responsibility of schools, departments, and programs in receipt of NSF funds to provide these discipline and career‐level appropriate programs or to provide referrals to appropriate existing programming. Suggested formats include case study reviews, discussion groups, journal clubs, etc. Schools, departments, and programs are encouraged to build upon existing RCR educational programming.

Washington University offers many educational opportunities in this area. To locate existing programming, please visit RCR Education at WashU.


Please access the WashU NSF COMPETES Procedures for compliance procedures, completion instructions, and specific qualifications for the continuing education requirement.

Roles and Responsibilities

Principal Investigator

The Principal Investigator (PI) is responsible for fostering an environment of and providing guidance in the ethical and responsible conduct of research for projects and individuals under their supervision. The PI must assure that individuals complete the appropriate education requirements related to ethical and responsible conduct of research, including the requirements outlined within this plan document.

For more specific information, visit Roles and Responsibilities – Principal Investigator.

School, Department or Program Administration

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

  1. inform appropriate individuals of their need to comply with this plan;
  2. provide face-to-face programming or referrals to appropriate programming that is discipline and career-level appropriate;
  3. provide appropriate information and resources to enable compliance within the specified timeline for completion;
  4. verify that appropriate individuals have complied with this plan within the applicable timeline for completion; and
  5. implement necessary internal procedures to assure that issues of noncompliance are identified and resolved.

For more specific information, visit Roles and Responsibilities – Department Administrator.

Office of Sponsored Research Services

The Office of Sponsored Research Services (OSRS) is responsible for providing institutional assurance of compliance with this plan to all applicable sponsors. OSRS will also monitor compliance with this plan.

Office of the Vice Chancellor for Research
The Office of the Vice Chancellor for Research (OVCR) is responsible for providing oversight, educational resources, and assurance of compliance with this plan.


Compliance with this plan will be monitored through a variety of existing mechanisms. Please see the WashU NSF COMPETES Procedures for additional information.


Issues of non-compliance that are identified through ongoing monitoring activities will be forwarded to the Vice Chancellor for Research who, as institutional official, 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 until compliance is obtained.


This plan was approved by the Executive Committee on Research on 12/21/2009.
This plan was revised by the Vice Chancellor for Research effective 07/31/2023.