Regulatory/Compliance Requirements

UCSF faculty members are required to conduct research and manage the financial aspects of research in compliance with University policy, federal and state laws, and sponsor requirements. Principal Investigators must ensure that they, their fellow investigators, students and staff meet compliance requirements, including any necessary training.

Common Compliance Areas

Harassment and Discrimination Protections

In accordance with Title IX of the Education Amendments of 1972, Federally-supported research and training must occur in a civil, safe, and respectful environment, free from discrimination and unlawful harassment, sexual or otherwise. Harassment of any kind including sexual harassment is not tolerated at institutions that receive Federal funding or anywhere that Federally-funded activities are conducted. 

UCSF has principles and policies that align with the Federal requirements.

 

Additional NIH Requirements

  • NIH Training Grant Applications require an additional institutional Letter of Support (flatten before uploading) ensuring that the University has proper policies, procedures, oversight, and practices in place to prevent discriminatory harassment and other discriminatory practices, and ensuring that the institution has adopted procedures to request prior approval of a change in the status of the PD/PI or other senior/key personnel if administrative or disciplinary action is taken that impacts their ability to continue in their role on the NIH award as described in the application. (NOT-OD-19-029, UCOP)
  • NIH recipients must comply with Federal civil rights laws that prohibit discrimination on the basis of race, color, national origin, age, sex (which includes discrimination on the basis of gender identity, sexual orientation, and pregnancy), and disability. Ensuring that meaningful steps are taken to provide access to persons with limited English proficiency and ensuring effective communication with persons with disabilities. (NOT-OD-23-047)
  • NIH-supported conferences and scientific meetings are expected to take steps to maintain a safe and respectful environment for all attendees by providing an environment free from discrimination and harassment. Just-In-Time materials for conference awards will include requirement of a “safety plan” that will be communicated to all conference/meeting attendees. (NOT-OD-22-074, Safety Plan and letter to conference participants templates)
  • NIH requires notification when the Program Director/Principal Investigator (PD/PI) or Senior Key Personnel named on the NIH Notice of Award (NoA) is removed or otherwise disciplined due to concerns about harassment, bullying, retaliation, or hostile working conditions. (NOT-OD-22-129)
    UCSF Reporting Procedures: Immediately upon knowledge of removal or disciplinary action involving the PD/PI or Senior Key Personnel named on the NIH NoA, email the UCSF Point of Contact (POC) for NIH reporting. The UCSF POC will complete and submit the report and coordinate any resulting administrative requirements.
  • NIH expects prior approval requests for change in status and change of recipient organization include mention as to whether the change is related to concerns about safety and/or work environments (e.g. due to concerns about harassment, bullying, retaliation, or hostile working conditions). (NOT-OD-20-124
    UCSF Reporting Procedures: Immediately upon knowledge of removal or disciplinary action involving the PD/PI or Senior Key Personnel named on the NIH NoA, email the UCSF Point of Contact (POC) for NIH reporting. The UCSF POC will complete and submit the report and coordinate any resulting administrative requirements.

Additional NSF Requirments

Guidance for Off-campus and Off-site Research Requirements for NSF Applications

The National Science Foundation (NSF) Proposal & Award Policies & Procedures Guide (PAPPG) 23-1 Chapter II.E.9 Safe and Inclusive Working Environments for Off-Campus or Off-Site Research, effective for proposals due on or after January 30, 2023.

To foster safe and harassment-free environments wherever science is conducted, each proposal that proposes to conduct research off-campus or off-site (e.g., data/information/sample collection off-campus or off-site, such as, fieldwork and research activities on vessels and aircrafts), the AOR is required to certify that the organization has a plan in place for that proposal:

  • The Project PI should download the NSF Off-Campus-Site plan template and adjust accordingly for the needs of the project. 
  • The plan should describe 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 verbal, physical, electronic, or in writing
    • Conduct that is unwelcome, offensive, indecent, obscene, or disorderly
  • The plan identifies steps that will be taken to nurture an inclusive off-campus or off-site working environment training, processes to establish shared team definitions of roles, responsibilities, and culture (UCSF Principles and Policies); and field support, such as mentor/mentee support mechanisms, regular check-ins, and/or developmental events.
  • The plan includes communication pathways (within the team and to the organization) that minimize singular points in the pathway (e.g., use of a single person overseeing access to a single satellite phone) and takes into account circumstances, such as involvement of multiple organizations or the presence of third parties in the working environment.
  • The plan accounts for the process or method for making incident reports as well as how any reports received will be resolved.
  • The plan will be disseminated by the Project PI to individuals participating in the off-campus or off-site research prior to departure.
  • The plan will not be submitted to NSF. Instead, OSR staff will upload the final plan to the Additional Documents section of eProposal (Find your OSR Support) prior to routing the proposal for approvals and submission to the sponsor. AOR sign-off will be achieve during routing after confirming the plan is uploaded in eProposal. Off-Campus or Off-Site Research Plans can be retrieved from the application record in eProposal if requested by NSF.

Safety Committees