NSF Safe and Inclusive Working Environments Plan for Off-Campus or Off-Site Research
Effective January 30, 2023, the NSF Proposal & Award Policies & Procedures Guide (PAPPG) was updated to incorporate Safe and Inclusive Working Environments for Off-Campus or Off-Site Research language (Chapter II.E.9) which describes the new requirement for the Authorized Organizational Representative (AOR) to certify that NC State University has a plan in place for safe and inclusive research for any proposal that proposes to conduct off-campus or off-site research.
NSF defines “off-campus or off-site research” for the purposes of this requirement as “data/information/ samples being collected off-campus or off-site, such as fieldwork on research vessels and aircraft.”
NC State University defines Off-campus as sponsored activities that take place on land, in buildings or facilities (e.g., research vessels) not owned or leased by NC State at locations where NC State’s facilities-related indirect costs do not cover these location costs.
The Plan
For any offsite or field work on a proposed NSF project, the Principal Investigator (PI)/Project team must establish a plan for that proposal that describes how the following types of behavior will be addressed:
- Abuse of any person, including, but not limited to, harassment, stalking, bullying, or hazing of any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; or
- Conduct that is unwelcome, offensive, indecent, obscene, or disorderly; AND
- Identify steps the proposing principal investigator(s)/project team will take to nurture an inclusive off-campus or off-site working environment.
NC State University’s regulations and policies including, but not limited to, Discrimination and Harrassment (Reg 04.25.02), Equal Opportunity, Non-Discrimination and Affirmative Action Policy (POL 04.25.05), Title IX Sexual Harassment Policy (04.25.07), and Campus/Workplace Violence Prevention and Management (04.05.02) support these goals.
University policies and expectations for proper conduct apply to all staff, faculty, and students whether on-campus or working, doing research, or engaging in scholarly activities or studying at an off-site location.
To reduce administrative burden on NC State faculty, SPARCS has created templates plans that includes instructions, University policy and procedure information, and fields for PIs to complete their project-specific information.
Templates and INstructions
Principal Investigator Responsibilities
- Determine whether any “off-campus or off-site research” will occur on their NSF-funded award.
- Complete the a template plan which will constitute documentation of the required plan for a Safe and Inclusive Work environment.
- Distribute a copy of this plan to each researcher in off-campus or off-site research prior to those individuals leaving campus to participate in the off-campus or off-site activities.
- Retain documentation of who received the plan and the plan itself in their grant files or in the departmental grant file. These records are subject to the same retention schedule as other grant-related administrative records.
Note: Proposers should not submit the plan to NSF for review unless specifically requested. Plans may be re-used and re-distributed for multiple off-campus research activities but must be updated if the specific content needs to change.
For solicitations not requiring the submission of the Plan to NSF, the University still requires a copy of the Plan at proposal submission stage to ensure that application package is complete in the event an award is made.
PINS Guidance
For each proposal that proposes to conduct research off-campus or off site, the Authorized Organizational Representative (AOR) must complete a certification that the organization has a plan in place for this proposal regarding safe and inclusive working environments. NSF has confirmed that this certification is inclusive of subrecipient organizations. Therefore, a copy of the NC State University plan and/or any subrecipient plans must be uploaded to PINS prior to proposal submission by the AOR.
For solicitations not requiring the submission of the Plan to NSF, the University still requires a copy of the Plan at proposal submission stage to ensure that application package is complete in the event an award is made.
If the SPARCS Operations team is not able to locate a plan within the applicable PINS record, the record will be returned. SPARCS requests that the College Research Office provide a comment in the PINS routing record indicating whether the plan is part of the proposal package to be submitted to NSF, or uploaded separately as internal documentation.
Key Policies and Procedures
All NC State University staff, faculty, and student workers are required by University policy to complete the Discrimination and Harassment Prevention and Response Training course.
NC State University fulfills NSF requirement, and it’s own expectations, through the non-comprehensive list of policies, regulations, and statutes outlined below, contemplated to cover special circumstances as dictated by the PI in the project-specific plan.
- POL 04.25.07 – Title IX Sexual Harassment Policy
- REG 04.25.08 – Title IX Sexual Harassment Resolution Procedure
- POL 04.25.05 – Equal Opportunity, Non Discrimination and Affirmative Action Policy
- POL 05.20.01 – Appointment, Reappointment, Promotion and Permanent Tenure
- POL 11.35.01 – Code of Student Conduct
- REG 04.05.02 – Campus/Workplace Violence Prevention and Management
- REG 04.25.02 – Discrimination, Harassment and Retaliation Complaint Procedures
- REG 04.25.06 – Equal Opportunity, Title IX and Non-Discrimination Training for Employees
- N.C. Gen. Stat. §14-196.3 (Cyberstalking)
- N.C. Gen. Stat. §14-269.2 (Weapons)
- N.C. Gen. Stat. § 14-277.3A (Stalking)
- N.C. Gen. Stat. §50B-1 et seq. (Domestic Protection)
- N.C. Gen. Stat. §50C-1 et seq. (Civil No Contact Orders)
Office for Institutional Equity and Diversity’s Policies and Procedures Related to Discrimination, Harassment and Retaliation website covers these and other resources available to the community. NC State’s Policies, Regulations, and Rules website contains the full listing of all university policies and procedures.
Reporting Obligation
Title IX Designated Official is personnel authorized by NC State to receive notice of Title IX Sexual Harassment and Retaliation and to institute corrective measures. Individuals may make a Report regarding Title IX Sexual Harassment, whether or not the person reporting is the person impacted by the alleged conduct. A responsible employee includes any employee who has been given the duty of reporting incidents of sex discrimination to the Title IX coordinator or other appropriate school designee. A complete list of responsible employees can be found here.
More information about reporting can be found on the Equal Opportunity and Equity unit’s reporting page.
Report to Risk Assessment Case Manager and Violence Prevention and Threat Management (General Info, Form). Reports can be submitted anonymously.
BIO and GEO Directorate Pilot
Beginning in March 2023, several solicitations from BIO and GEO will require the submission of a Safe and Inclusive Working Environments Plan for research proposals (vs. education/ training) that will be considered as part of the Broader Impacts criteria during the review process. Additional Directorates are also expected to include this requirement in throughout 2023, details can be found here and a list of FAQs can be found here. Special attention should be given to the requirements of solicitations from BIO and GEO Directorates.
In general, the alternate plan requires a two page supplemental document to be submitted with the proposal. In the event an NSF directorate requires an alternative arrangement, follow NSF’s instructions rather than the general ones provided here.
Principal Investigators and College Research Offices are advised to pay special attention to the requirements of solicitations from BIO and GEO Directorates.
FAQs
What does “off-campus” or “off-site” mean?
The intent of this requirement is to provide guidance and protection for researchers when they do not have ready access to the on-campus, in-person resources they normally do. If researchers are off-campus such that access to these resources is more limited than they would be if they were on campus, then a plan is needed.
When in doubt, create a plan.
What does NSF mean by “research activities”? Is a plan required if my NSF work is considered an “other sponsored activity”?
The new requirement applies only to research activities. NSF has defined off-campus or off-site research for the purpose of these requirements as “data/information/samples being collected off-campus or off-site, such as fieldwork or research activities on vessels and aircraft.”
Principal Investigators are responsible for determining whether the requirement applies to their overall project or to certain activities on their project. If there is a research component on an award that is otherwise characterized as an “other sponsored activity”, then the plan should address only the research component.
Who is included in the definition of a “Participant” or “Researcher”? Does this include subrecipient personnel? Other faculty working at the off-campus location with the PI?
“Participants” and “Researchers” are NC State University employees, students, volunteers, and others working under NC State University’s direction, including contractors. It is expected that subrecipient personnel will be operating under their own Institution’s plan for their off-site activity. NC State Principal Investigators should verify with the PI at the subrecipient organization that this has occurred.
Typically, an NC State PI will only assume responsibility for NC State participants/researchers but there may be cases where participants or researchers from other entities may need to use NC State’s plan. This may be allowed but should be discussed with the College Research Office in advance, as it places a special administrative burden on NC State as these participants will not already be familiar with NC State policies or practices, and special coordination across entities may be needed.
How do separately submitted collaborative proposals comply with this
requirement?
If more than one collaborating organization proposes to conduct research off-campus or off-site, one joint plan must be developed, unless otherwise specified in a program solicitation.
Must the plan be in place prior to proposal submission?
Yes, the language contained in the certification was carefully crafted to require that the organization has a plan in place for that proposal that describes how the types of behavior specified in Chapter II.E.9 will be addressed.