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Research Integrity and Compliance Training Research Integrity and Compliance Training

Last updated: October 31, 2025

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Policy Statement

Emerson College expects faculty, staff, and students to conduct their work, including sponsored projects and research, with the highest degree of integrity. Likewise, federal sponsors are increasingly imposing requirements for grantee institutions to demonstrate the proficiency of their investigators in the ethical considerations inherent in research. These requirements reflect a shared societal concern for the proper stewardship of public dollars in support of research, the ethical treatment of human subjects, and the humane care and use of animals in research. Emerson College shares these commitments, and therefore mandates the training requirements detailed below.

Reason for the Policy

This policy constitutes the minimum standards set forth by Emerson College for mandatory training pertaining to federal research funding. Ethical and responsible conduct of research is critical for excellence, as well as public trust. Consequently, education in the responsible and ethical conduct of research is considered essential in the preparation of future researchers, and is required as a condition of funding from the National Science Foundation, the National Institutes of Health, and other federal sponsors of research. Emerson College is thus committed to providing faculty, staff, and students with the training and resources that will equip them with the knowledge, skills, and tools necessary for the responsible conduct of research.

Definitions

  • CITIProgram. The Collaborative Institutional Training Initiative (CITI), a web-based platform that provides training and certifications in areas of research compliance for Emerson faculty, staff, and students.
  • Institutional Review Board (IRB). A committee consisting of faculty and staff that is responsible for the review, approval, and oversight of research involving human subjects conducted under the auspices of the College.
  • Other Support. A comprehensive listing –required by the National Institutes of Health– of all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the researcher's home institution
  • Responsible and Ethical Conduct of Research (RECR) training. A training framework and requirement for personnel on grants from the National Science Foundation (NSF) and the National Institutes of Health (NIH). RECR training must cover topics that are considered critical to conducting research in an ethical, legal and responsible manner, including conflicts of interest, research integrity, proper stewardship of intellectual property, and ethical mentoring and collaboration.
  • Research Security Training. A training framework and requirement for personnel on grants from the NSF and the NIH. A proposing institution must have comprehensive, certificate-based training in place that covers cybersecurity, international collaboration, foreign interference, rules for proper use of funds, disclosure, conflict of commitment, and conflict of interest.

Statements of Elaboration of the Policy

I. Types of Training and Applicability

There are four areas of research integrity training covered by this institutional policy:

  1. Responsible and Ethical Conduct of Research (RECR) training. Required for all named individuals working on grants funded by the National Science Foundation or the National Institutes of Health (NIH).
  2. Research Security Training - effective October 10, 2025 (required for ALL senior/key personnel on certain federally funded research grants)
  3. Other Support Training - effective October 1, 2025 (required for ALL senior/key personnel on National Institutes of Health (NIH) proposals and awards)
  4. Protection of Human Subjects training (required for ALL individuals conducting research with human subjects, regardless of funding source).

II. Responsible and Ethical Conduct of Research (RECR) Training

A. Applicability

This RECR training requirement applies specifically to federally sponsored research supported by the National Science Foundation or the National Institutes of Health. The policy does not apply to other types of externally sponsored/funded projects. Projects that do not require RECR training are still subject to the College's policy on Ethics and Conflict of Interest.

No research activities may be conducted –and access to federal research funds may be withheld– until all required personnel have completed the required RECR training, and certification for completion has been received by ORCS.

B. Sponsor-Specific Requirements

The sponsor-specific requirements are as follows–

  • National Science Foundation (NSF): Responsible and Ethical Conduct of Research (RECR) training must be completed once by undergraduate students, graduate students, postdoctoral scholars, faculty, and other senior personnel who will be supported by NSF to conduct research. The training must cover the following topics:
    • Research Misconduct
    • Data Management/Safeguarding Intellectual Property
    • Conflicts of Interest and Commitment
    • Research Involving Human Subjects
    • Mentoring and Healthy Research Environments
    • Authorship and Publication

Recommended but not required:

  • Peer Review

NSF also expects that RECR training will include ongoing mentorship and discussion on the responsible conduct of research.

Per NSF's guidelines, all personnel on NSF-funded research must retake RECR training every four years.

  • National Institutes of Health (NIH): NIH policy requires that faculty, research associates, postdoctoral fellows, and other senior/key personnel complete RECR training "at least once during each career stage," or no less than once every four years, and cover most or all of the following topics:
    • Conflicts of interest (personal, professional, and financial)
    • Policies regarding human subjects, live vertebrate animal subjects in research, and safe laboratory practices
    • Mentor/mentee responsibilities and relationships
    • Collaborative research including collaborations with industry
    • Peer review
    • Data acquisition and laboratory tools; management, sharing and ownership
    • Research misconduct and policies for handling misconduct
    • Responsible authorship and publication
    • The scientist as a responsible member of society, contemporary ethical issues in biomedical research, and the environmental and societal impacts of scientific research

In addition to completing the online training, NIH expects "discussion-based instruction" and "substantive face-to-face interaction among participants and faculty" to be a key feature of any NIH Training Grant, or grant that includes a Post-Doctoral Fellow. For questions or assistance, contact the orcs [at] emerson.edu (Office of Research and Creative Scholarship).

C. Online Training Component

Emerson has subscribed to the Collaborative Institutional Training Initiative (CITI) to provide online RECR training and certification.To complete the training, please visit the CITI website and complete the following steps:

  1. Click on "Register", then "Select Your Organization Affiliation" Search for and select "Emerson College," then follow the prompts to complete your affiliated registration. This is essential so that Emerson receives proof of your completion of training via a system-generated notification.
  2. Select the Responsible Conduct of Research course based on your discipline (e.g., Humanities, Social & Behavioral Sciences, Physical Sciences etc.).
  3. Complete the online readings and quizzes for all modules specified for either NSF or NIH, as listed above.

It is recommended that you NOT try to complete the training in a single session. Each time you log in, you will be able to continue from where you previously left off. You can repeat quizzes and readings as many times as needed.

Upon completion of the course, the Office of Research and Creative Scholarship will automatically receive a completion notification for the individual which will be kept on file and made available to external sponsors upon request. Training certifications are valid for a period of four years, after which time it is the individual's responsibility to complete a "refresher" CITI module.

Faculty, staff, and students conducting research activities not supported under other (Non-NIH or non-externally sponsored projects) are not required to complete RECR training, but are strongly encouraged to do so. Additionally, faculty are encouraged to consider ways in which the CITI RECR training modules may be incorporated into their course work to enhance student understanding of research ethics.

III. Research Security Training

A. Applicability

Individuals identified as senior/key personnel on proposals to NSF and NIH must complete security training that meets the requirements of Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234).

B. Requirement

Effective October 10, 2025, individuals identified as senior/key personnel on proposals to NSF and NIH must complete training that addresses cybersecurity, international collaboration, foreign interference, and rules for proper use of funds, disclosure, conflict of commitment, and conflict of interest. This training must be completed within 12 months prior to a proposal submission to NSF or NIH.

C. Online Training Component

The SECURE Center at the University of Washington has created a condensed Research Security Training (RST) module that meets the government-wide requirements of the CHIPS and Science Act. This module is available for Emerson affiliates in Workday Learning (Research Security Training for Federal Grants). To complete the training, go to Workday, log in with your Emerson credentials, and complete the following steps:

  1. Log in to Workday using your Emerson credentials.
  2. Select "Learning" from the main menu.
  3. Search for and select "Research Security Training for Federal Grants".
  4. Take the entire course, which consists of four sections and periodic short quizzes. The entire module is about ninety minutes in length.
  5. Download your certificate of completion and email it to the orcs [at] emerson.edu (Office of Research and Creative Scholarship).

This training must be completed once, and prior to the submission of a proposal to NIH or NSF after October 10, 2025.

IV. Training on NIH "Other Support Disclosure" Requirements

A. Applicability

Individuals identified as Senior/Key personnel on NIH proposals and awards who are required to provide "Just-In-Time" information to NIH during the application process.

B. Requirement

Effective October 1, 2025, NIH requires that training must be implemented for Senior/Key Personnel in the disclosure of research activities and affiliations (active and pending) in the Other Support form. Institutions must ensure that Senior/Key Personnel fully understand understand their responsibility to disclose all resources made available to the researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.

C. Online Training Component

The Workday Learning module designed for Research Security training (Research Security Training for Federal Grants) includes sections on the appropriate disclosure of other support. To complete the training, go to Workday, log in with your Emerson credentials, and complete the following steps:

  1. Log in to Workday using your Emerson credentials.
  2. Select "Learning" from the main menu.
  3. Search for and select "Research Security Training for Federal Grants".
  4. Take the entire course, which consists of four sections and periodic short quizzes. The entire module is about ninety minutes in length.
  5. Download your certificate of completion and email it to the orcs [at] emerson.edu (Office of Research and Creative Scholarship). Completing this course also fulfills the Research Security Training requirement outlined in this policy.

Additionally, a more comprehensive module on disclosure is available on NSF's Research Security Training website. While not required, individuals identified as Senior/Key Personnel on an NIH proposal are strongly encouraged to supplement the Workday Learning training with this module. A downloadable certificate of completion is provided at the end of the module, which should be forwarded to the orcs [at] emerson.edu (Office of Research and Creative Scholarship).

D. Additional "Other Support" Resources

V. Protection of Human Subjects Training

A. Applicability

This training requirement applies to all faculty, staff, or students conducting activities that meet the definition of human subjects research, regardless of whether those activities are externally funded, internally funded, or unfunded. All researchers on a human subjects research study must be CITI-certified using the courses below prior to their study receiving Institutional Review Board (IRB) approval. Individuals needing clarity on whether their activity meets the definition of human subjects research should contact the human_subjects [at] emerson.edu (IRB Chair). A researcher, student or faculty member should not make this determination independently.

B. Requirement

Individuals conducting human subjects research are required to complete one of two CITI online training courses, as detailed below–

C. Online Training Component

To complete the training, please visit the CITI website and complete the following steps:

  1. Go to CITIProgram.org
  2. Register to create an account. Be sure to affiliate with Emerson College during registration.
  3. When asked to select your curriculum, choose Social & Behavioral Research under Question 2.
    1. If you choose to register for the GCP - Social and Behavioral Research Best Practices for Clinical Research course, choose it in Question 4.
  4. Complete the selected course.

Training certifications are valid for a period of four years, after which time it is the individual's responsibility to complete a "refresher" CITI module.

Faculty, staff, and students are reminded that no research with human subjects may be conducted without the advance review and approval of the Emerson College IRB. IRB protocols will not be approved without documentation of the completion of the required training by the Principal Investigator and all research staff named on the protocol. It is the Principal Investigator's responsibility to ensure each current or future member of his/her research team (including students) engaged in human subjects research also completes the training course.

If you need assistance registering with CITI, or require additional information on any of the College's research training requirements, please contact the orcs [at] emerson.edu (Office for Research and Creative Scholarship).

Key Office to Contact Regarding this Policy and its Implementation

The Office for Research and Creative Scholarship at Emerson College is responsible for the oversight and implementation of this policy.

The Responsible Officer for this policy is the Provost and Vice President of Academic Affairs. Questions relating to the implementation of this policy should be directed to the Office of Research and Creative Scholarship, or the appropriate Vice Presidents for aspects of implementation for which they are responsible.