Policy on Required Disclosures and Research Security Training for Research Key Personnel

1. Purpose

The purpose of this policy is to demonstrate the Institute’s commitment to the integrity and security of its research by underscoring the importance of compliance with federal disclosure and training requirements related to research. This policy will ensure all Senior/Key Personnel understand their responsibilities to disclose all resources made available to them in support of and/or related to their research activities, regardless of monetary value and whether or not such resources are based at Rensselaer Polytechnic Institute.

2. Scope

This policy applies to all faculty, researchers, and staff named as Senior/Key Personnel on federally-funded projects at RPI.

3. Definitions

Other Support - Includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of monetary value or whether they are based at the institution identified for the current grant.

Senior/Key Personnel - Individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, regardless if salaries are requested. Typically, these are designated or named by RPI in proposals and approved by Federal sponsors, and are PDs/PIs or Co-Is (and have doctoral degrees), however some staff or students at the masters or baccalaureate level may also be considered if their involvement meets the definition.

Covered Individual – An individual who: (a) contributes in a substantive, meaningful way to the development or execution of the scope of work of a project or proposed for funding; and (b) is designated as a covered individual. At a minimum, “covered individuals” are designated by any principal investigator (PI); project director (PD); co-principal investigator (Co-PI); co-project director (Co-PD); project manager; and any individual regardless of title that is functionally performing as a PI, PD, Co-PI, Co-PD, or project manager. Status as a consultant, graduate (master’s or PhD) student, or postdoctoral associate does not automatically disqualify a person from being designated as a “covered individual” if they meet the definition in (a) above.

4. Policy

4.1 Other Support Training – All Senior / Key Personnel or Covered Individuals named on federal or federal passthrough proposals must complete the RPI-offered Research Security course annually or within 12 months prior to proposal submission.

Other Support Disclosure – Senior / Key Personnel or Covered Individuals named in proposals must disclose Other Support per federal agency requirements.

Other Support Reporting – Each Senior / Key Personnel or Covered Individual is responsible for disclosing and reporting Other Support via the federal agency described methods (i.e., electronic signature of the Other Support form prior to submission certifying true, complete, and accurate statements).
1. Responsibilities:

Senior / Key Personnel or Covered Individuals – Ensure timely and accurate disclosure of Other Support. Complete required Research Security Training per federal agency policy.
Research Compliance – Ensure the Research Security Training is available for completion.
Research Administration and Finance – Ensure completion of Research Security Training at time of proposal.
Research Security and Export Control – Conduct risk-based monitoring of training and disclosures; conduct ad hoc training and serve as an expert resource to faculty and administrators for all federal research security requirements.
1. Enforcement:
Non-compliance with training requirements will result in proposals being held or withdrawn.
Faculty who receive federal awards but have not completed training will have their award accounts held until training has been completed.
Personnel who are required to complete research security training cannot work or be paid on federal awards until training has been completed.
Inadvertent failure to adequately disclose outside research activities in accordance with Sponsor requirements may result in award declinations, significant delays in award negotiations, requirements for research security risk mitigation (including suspension of certain activities), or other Institute disciplinary action.
Intentional omission of required disclosures or misrepresentations could result in criminal prosecution and liability, pursuant to, but not limited to, 18 U.S.C. §§ 287, 1001, 1031 and 31 U.S.C. §§ 3729-3733 and 3802.

Office of the General Counsel