Responsible Conduct of Research (RCR) Training is required for NSF, NIH, and USDA-NIFA awards. Senior/key personnel, faculty, undergraduate students, graduate students, and postdoctoral scholars who receive support from the grant award must complete this training before engaging in the research activity. 

RCR Training is completed through the online CITI Program and is valid for four years. 

CITI Login Instructions

For CWU Personnel (faculty, staff, students)

1. Log into CITI using your CWU credentials: https://www.citiprogram.org/index.cfm?pageID=668
2. Select “Add a Course”
3. Select “Research on a federally funded grant(s) (e.g., NSF, NIH, DOD, USDA, NASA, etc)” for the first question.
4. Select trainings as applicable. You may select “Not at this time” for any trainings you do not need.
5. Complete the required training(s). You may do so in multiple sessions. You must achieve an average score of at least 80% on all quizzes to proceed through each module and successfully complete the training.

For Non-CWU personnel, please contact the CITI administrator, Mason Low at lowm@cwu.edu to be added.

Contact the CITI administrator, Mason Low, at lowm@cwu.edu if your are experiencing technical issues. 

CWU RCR Policy

CWU requires all employees to annually disclose any personal or business interests and relationships that reasonably could give rise to a perceived, potential, or real conflict of interest (COI). 

In addition, COI disclosure is required for all classified/exempt staff and PIs/co-PIs (and any other individual in which there may be a perceived COI) on NSF, NIH, USDA, NASA, DOD, EPA and Energy grants. This ensures transparency, integrity, and objectivity in research. It helps funding agencies identify and manage any potential financial or personal interests that could bias the design, conduct, or reporting of research. This protects the credibility of the research and maintains public trust in the scientific process. 

Complete your electronic COI disclosure form here or contact Internal Audit with questions in the disclosure process. 

Policies

• CWU 301-26: Conflict of Interest Standards Policy - All Employees
• CWU 502-03: Research Ethics and Conflicts of Interest
• CWU 701-06: Conflict of Interest in Relationships

COI Training - Senior/key personnel on NIH grants are required to complete COI training through the online CITI Program and is valid for four years. 

CITI Login Instructions

For CWU Personnel (faculty, staff, students)

1. Log into CITI using your CWU credentials: https://www.citiprogram.org/index.cfm?pageID=668
2. Select “Add a Course”
3. Select “Research on a federally funded grant(s) (e.g., NSF, NIH, DOD, USDA, NASA, etc)” for the first question.
4. Select trainings as applicable. You may select “Not at this time” for any trainings you do not need.
5. Complete the required training(s). You may do so in multiple sessions. You must achieve an average score of at least 80% on all quizzes to proceed through each module and successfully complete the training.

For Non-CWU Personnel (contact lowm@cwu.edu)

Contact the CITI administrator, Mason Low, at lowm@cwu.edu if you are experiencing technical issues. 

Introduction

Export control laws are federal regulations that govern the transfer of controlled information, technologies, and commodities to foreign nationals or foreign countries for reasons of national security, foreign policy, and nonproliferation. As a university involved in research, international collaboration, and global exchange of knowledge, it is critical that our community understands and complies with these regulations when the research/project is sponsored by a federal entity. The three main regulatory bodies include:

• Export Administration Regulations (EAR) – administered by the Department of Commerce (15 CFR §§ 730–774)
• International Traffic in Arms Regulations (ITAR) – administered by the Department of State (22 CFR §§ 120–130)
• Office of Foreign Assets Control (OFAC) – administered by the Department of the Treasury

Export Control Activities

The following activities on an externally sponsored project or research activity may be subject to export control regulations:

• Research involving controlled equipment or technology,
• International travel with university equipment or data,
• Collaborations with foreign researchers or institutions,
• Hosting foreign visitors in labs,
• Sharing research results before publication,
• Working with embargoed countries or restricted parties,
• Shipping of tangible items outside the United States

International Travel and Research

If traveling and/or doing research internationally and taking a laptop, tablet, or other electronic mobile device, this is a controlled device.

There may be limitations for taking these devices into certain countries. Reviewing restrictions each time international travel occurs is advised. While traveling the device should be free from customized software or stored or accessible controlled technology. Any ITAR controlled software or technology requires a license before traveling and additional security measures should be taken with EAR software and technology to prevent unauthorized dissemination.

Do not take these controlled devices or ship them to the following locations without first reviewing the OFAC imposed country or regional sanctions list. If it is determined that travel will be to a sanctioned country, please contact the Pre-Award and/or Grant/Contract Accounting Office to request a “clean” laptop for travel that is free of any controlled or sensitive data, software, or technology.

Required Export Control Training on Externally Sponsored Awards

If traveling internationally on an externally sponsored project, export control training through CITI must be completed prior to the Grant/Contract Accounting Office approving an individual’s Travel Authorization. Export control training is valid for four years. 

CITI Login Instructions

For CWU Personnel (faculty, staff, students)

1. Log into CITI using your CWU credentials: https://www.citiprogram.org/index.cfm?pageID=668

2. Select “Add a Course”

3. Select “Research on a federally funded grant(s) (e.g., NSF, NIH, DOD, USDA, NASA, etc)” for the first question.

4. Select trainings as applicable. You may select “Not at this time” for any trainings you do not need.

5. Complete the required training(s). You may do so in multiple sessions. You must achieve an average score of at least 80% on all quizzes to proceed through each module and successfully complete the training.

For Non-CWU Personnel (contact lowm@cwu.edu)

Contact the CITI administrator, Mason Low, at lowm@cwu.edu if you are experiencing technical issues. 

It is the policy of CWU to neither condone nor tolerate research/scholarly misconduct by any member of its community. Research misconduct includes: 

• Fabrication – making up data or results.
• Falsification – manipulating research processes or altering data.
• Plagiarism – using others’ work or ideas without proper attribution.

Malign Foreign Talent Recruitment Program (MFTRP) Certification - a compliance requirement related to national security and research integrity. It specifically targets the risks posed by foreign talent recruitment programs that are deemed to be malign—meaning they may be used by adversarial nations to steal intellectual property, influence researchers, or transfer sensitive technology.

NSF, NIH, DOE, DOD and NASA require that proposers, covered individuals, and senior/key personnel certify that they are not a party to a malign foreign talent recruitment program. Participation in a MFTRP is strictly prohibited. This is in accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232). 

Malign Foreign Talent Recruitment Programs are defined in the Chips & Science Act of 2022 as:

• (A) any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual –  
  • (i) engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products; 
  • (ii) being required to recruit trainees or researchers to enroll in such program, position, or activity; 
  • (iii) establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award; 
  • (iv) being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances; 
  • (v) through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award; 
  • (vi) being required to apply for and successfully receive funding from the sponsoring foreign government’s funding agencies with the sponsoring foreign organization as the recipient; 
  • (vii) being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award; 
  • (viii) being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or
  • (ix) having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award. And,
• (B) A program that is sponsored by – 
  • (i) a foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern; [Countries of concern are China, Iran, North Korea, and Russia. CHIPS also notes that “entities” located outside of a foreign country of concern but owned, controlled, or subject to the jurisdiction of a country of concern are also subject to restrictions.]
  • (ii) an academic institution on the list developed under section 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 ( 10 U.S.C. 2358 note; Public Law 115– 232 ); or
  • (iii) a foreign talent recruitment program on the list developed under section 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 ( 10 U.S.C. 2358 note; 1 Public Law 115–232 ).

All senior/key personnel on proposals to or awards from the National Institutes of Health (NIH) must disclose all research activities and affiliations (active and pending) in Other Support. All senior/key personnel must fully understand their responsibility to disclose all resources made available to them 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.

Training is completed prior to proposal submission through the online CITI Program, is valid for one year, and requires annual renewal [refresher course]. Completing the CITI Responsible Conduct of Research (RCR) and/or Research Security Training (RST) courses will meet this NIH training requirement. Each of these trainings have a training module discussing the requirement of other support disclosure. See below for CITI login instructions. 

In addition, all senior/key personnel are also required to review the following information:

• NIH Other Support Resource Website (includes requirements, forms, samples, instructions, FAQs, etc.)
• NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support (PDF)

CITI Login Instructions

For CWU Personnel (faculty, staff, students)

1. Log into CITI using your CWU credentials: https://www.citiprogram.org/index.cfm?pageID=668
2. Select “Add a Course”
3. Select “Research on a federally funded grant(s) (e.g., NSF, NIH, DOD, USDA, NASA, etc)” for the first question.
4. Select trainings as applicable. You may select “Not at this time” for any trainings you do not need.
5. Complete the required training(s). You may do so in multiple sessions. You must achieve an average score of at least 80% on all quizzes to proceed through each module and successfully complete the training.

For Non-CWU Personnel (contact lowm@cwu.edu)

Contact the CITI administrator, Mason Low, at lowm@cwu.edu if you are experiencing technical issues.