Research Training Standards

Research Compliance

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Purpose

Western Washington University is committed to responsible and ethical research, in compliance with all federal, state, local, sponsor, and university requirements. This standard establishes training requirements for all researchers engaged in certain types of research projects including those that are externally sponsored including but not limited to the National Science Foundation (NSF) and the National Institutes of Health (NIH). The purpose of these trainings is to ensure compliance with federal regulations, foster a culture of ethical and responsible research, and safeguard the integrity, security, and public trust in the WWU's research community.

Who does this apply to? 

All faculty, staff, students, and postdoctoral scholars participating in research sponsored by the NSF, NIH, and/or other federal agencies as specified in the requirements below.

Roles and Responsibilities

  • Principal Investigators (PIs): Ensure that all project personnel complete required training prior to engaging in research.
  • Researchers (paid or unpaid): Complete assigned training in a timely manner and comply with federal and institutional policies.
  • Research Integrity and Compliance: Provide training resources, track completion, and verify compliance for Responsible Conduct of Research, Research Security Training, and Conflict of Interest training requirements.
  • Human Research Protections Program (HRPP): Provide training resources to all WWU faculty, staff, and students involved in human participant research; review human participant research submissions and track progress on protocols determined to be Expedited or Full Board; and verify compliance with human participant training requirements on all active submissions.
  • Animal Care and Use Program (ACAUP): Provide training resources to all WWU faculty, staff, and students involved in animal research/teaching; review animal research/teaching submissions and track progress on protocols and modifications; and verify compliance with animal research training requirements on all active submissions.

Responsible Conduct of Research (RCR)

In 2007, Congress passed the America COMPETES (Creating Opportunities to Meaningfully Promote Excellence in  Technology, Education, and Science) Act, which required that "each institution that applies for financial assistance from NSF for science and engineering research or education describe in its grant proposal a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate students, graduate students, and postdoctoral researchers participating in the proposed research project."  NIH mandates that trainees on an NIH institutional research training grant, individual fellowship, career development award (institutional or individual), research education grant, dissertation research grant, or other grant programs that have a significant training component have a minimum of eight hours of formal instruction at least once during each career stage and at least every four years. 

Format: WWU primarily fulfills this obligation through the CITI Program which provides nationally recognized, peer-reviewed, online regulatory content for researchers.

Frequency: Training must be completed upon joining a federally funded research project and is valid for three years after which a refresher course is required to maintain compliance.

Research Security Training

The NSF, NIH, DOE, DOD, and NASA require that proposers, covered individuals, and senior/key personnel complete research security training. This is in accordance with National Security Presidential Memorandum 33 (NSPM-33) and Section 10634 of the CHIPS and Science Act of 2022. This training addresses cybersecurity, international collaboration, foreign interference, and rules for proper use of funds, disclosure, conflict of commitment, and conflict of interest, which meets the government-wide training requirement. 

Format: WWU utilizes the CITI Program to maintain compliance with this training requirement.

Frequency: 

  • NSF projects: For proposals submitted on/after 10/1/2025, proposers and individuals identified as senior/key personnel by the proposer within 12 months prior to proposal submission.
  • NIH projects: Starting 5/25/2026 Each individual identified as a senior/key person must certify that they have completed the training specifically covering 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.
  • NASA projects: Beginning 8/5/2026 any Principal Investigator (PI) (regardless of level of effort), any CoPI (regardless of level of effort), and only Co-Investigators proposing to spend ten percent or more of their time in any given year on a NASA-funded award will be required to certify that they have completed research security training within the last year. Any covered individual that joins a NASA-funded project after an award has been issued shall also submit biographical sketch and current and pending (other) support forms and attest that they have taken the requisite research security training. 

Financial Conflict of Interest (FCOI)

In alignment with WWU's Conflict of Interest policy investigators must disclose any significant financial interests to the institution. Per 42 CFR 50.604 of Subpart F – Promoting Objectivity in Research, researchers funded by the Public Health Service (PHS) are required to complete Financial Conflict of Interest training.

Format: WWU satisfies the FCOI training requirements with CITI Program training. Research Integrity and Compliance oversees compliance with this training. 

Frequency:  Initial training prior to engaging in PHS-sponsored research and at least every four years thereafter, or immediately if: 

  • The Institution revises its financial conflict of interest policies or procedures in any manner that affects the requirements of Investigators
  • An Investigator is new to an Institution
  • An Institution finds that an Investigator is not in compliance with the Institution's financial conflict of interest policy or management plan. 

NIH Disclosure Training

NIH supported Senior/Key Personnel must complete training to disclose all research activities and affiliations (active and pending) in Other Support (see Other Support form). This new requirement to train researchers to comply with other support disclosure requirements adds to the current policy (see NIH Grants Policy Statement (GPS), Section 2.5.1 "Just-in-Time Procedures") in order to provide a comprehensive plan in the area of disclosure requirements for recipients.

Effective October 1, 2025, NIH senior/key personnel must complete trainings on requirements for the disclosure of other support to ensure they fully 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.

Format: WWU utilizes the CITI Program to fulfill this obligation.

Human Participant Research Training

In compliance with federal regulations (45 CFR 46, 21 CFR Parts 50 and 56) and institutional policies, WWU requires that all researchers conducting research involving human participants to complete training in human participant protections. 

Format: WWU uses the CITI program to satisfy the human participant training requirements. The HRPP oversees compliance with this training as part of the review process of all HRPP submissions (initial submissions and personnel modifications).

Frequency: The WWU HRPP requires that you complete the basic refresher course every 5 years. You are responsible for ensuring all key personnel maintains current training. Federal funding agencies and some other external agencies require a refresher course/certification every 3 years.

Animal Research Trainings

Animal welfare and protections training documentation must be on file prior to any interaction or intervention with live vertebrate animals in research or teaching settings. A basic training on the protection of animal subjects used in research is required for all personnel working with research/teaching animals. Species specific training may also be required. Additional laboratory training may also be required for specific IACUC approved protocols. 

Format: WWU employs the CITI program to satisfy the animal welfare and protections training requirements. The ACAUP oversees compliance with this training as part of the review process of all protocol submissions (initial submissions and personnel modifications).

Frequency: Training must be completed every 3 years.

Updated 10/9/2025