NSF Safe and Inclusive Working Environment Plan for Off-campus or Off-site Research

Office of Research and Creative Scholarship/Office of Sponsored Programs

 January 30, 2023

The National Science Foundation’s (NSF) new Proposal & Award Policies & Procedures Guide (PAPPG 23-1), effective for proposals with off-campus or off-site work due on or after January 30, 2023, requires principal investigators (PIs) to certify that they have a plan for creating and maintaining a Safe and Inclusive Working Environments for Off-Campus and Off-Site Research. NSF recognizes that a community effort is essential to eliminate sexual and other forms of harassment in science and to build inclusive scientific climates where all students and employees can learn, grow, and thrive. The University of Montana wholeheartedly supports these goals.

INSTRUCTIONS FOR NSF PRINCIPAL INVESTIGATORS WITH OFF-CAMPUS OR OFF-SITE RESEARCH

  1. Determine whether the proposal contains “off-campus or off-site research” which is defined as “data/information/samples being collected off-campus or off-site, such as fieldwork or research on vessels and aircraft.” A plan and certification are only required for NSF-funded awards containing research that is conducted off-site or off-campus.
  2. Create, sign, and submit an “Communications and Response Plan” (hereafter, “CRP”) to your pre-award officer in OSP. In addition to identifying all participating UM personnel (students and employees) and the off-site/off-campus locations, the CRP provides instructions on how to report:
  3. 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; and
  4. Conduct that is unwelcome, offensive, indecent, obscene, or disorderly.
  5. Distribute the CRP to all UM personnel (students and employees) that will participate in the remote research activities prior to entering the field. The PI is responsible for ensuring that the CRP is provided to any personnel that join the project at a later time.
  6. Retain a copy of the CRP and records of who received the CRP (email or sign up sheet is sufficient) in your grant files. The CRP will not be submitted to NSF unless requested.

Note: CRPs may be re-used and re-distributed for multiple research activities but must be updated to reflect the specific needs and circumstances of each project.

References & Resources:

FREQUENTLY ASKED QUESTIONS 

QUESTION 1: What does “off-campus” or “off-site” mean? My research will take place at a healthcare clinic located in a city - does this new requirement apply?

Answer: The intent of this requirement is to provide guidance and protection for participants when they do not have ready or reliable access to UM student and employee resources or emergency responder services. If your researchers will have such access, no CRP is needed. If participants are sufficiently distant from campus that access to these resources is more limited than they would be if they were on campus, then a plan is likely needed.

QUESTION 2: What does “research activities” mean? I don’t do research; my NSF work is considered an “other sponsored activity.”

Answer: This new requirement applies only to research activities. NSF has defined off-campus or off-site research for the purpose of this requirements as “data/information/samples being collected off-campus or off-site, such as fieldwork or research activities on vessels and aircraft.” PIs are responsible for determining whether the requirement applies to their project or to certain activities on their project.  If there happens to be a research component on an award that is characterized as an “other sponsored activity,” then the requirement only applies to the research component.

QUESTION 3: I forgot to send a CRP to one or more research participants before we left; what do I do now?

Answer: If the off-site research is still taking place, send the CRP now to all participant(s). If the off-site research is over, send an email to your OSP post-award officer explaining the circumstances. OSP will confer with the PI on appropriate next steps (NSF has not identified what corrective actions should be taken, but most likely it will involve an uninvolved third-party checking with the participant to ascertain whether there were any issues that arose while off-campus that made the participant feel unsafe or needed reporting.) 

QUESTION 4: Who counts as a “participant?” Does this include subrecipient personnel? Other faculty working at the off-campus location with the PI?

Answer: The NSF requirement includes all UM participants. For subrecipient personnel, their own institution should have issued a plan for the off-site activity (PIs should verify with the PI of the subrecipient organization that this has occurred). UM’s CRP may be shared and adapted for use by the subrecipient.

QUESTION 5: Is it possible to name a backup point of contact listed on the CRP?

Answer: Yes. is advisable to have a primary and a secondary point of contact available. The Principal Investigator must be listed on the CRP in the “PI” box but may also be listed as the primary point of contact, or they may delegate the primary point of contact responsibility to another individual who is present at the off-campus location. Please include the cell phone number, email, and other contact information (e.g., remote site location, satellite text messenger contact information and instructions. and email of the alternative contact.

QUESTION 6: What should happen if the person doing the alleged misconduct is the named point of contact? 

Answer: As described above, it is helpful to list contact information for two individuals (e.g., the PI and a second delegated person) so that there is a local second point-of-contact readily available  Assuming there is internet or cell phone service, the participant can also use one of the other reporting mechanisms to contact their supervisor or a University official responsible for handling misconduct concerns. If the participant is unable or unwilling to notify the primary point of contact and the standard reporting options are not available, the participant may defer reporting until access is available (if they feel it is safe to do so), or approach another senior person on the off-campus team (whether or not from UI) to assist them in appropriate next steps. 

QUESTION 7: I am the PI and I do have special off-site circumstances. What are my options?  

Answer: PIs may devise options they believe are appropriate to the circumstances, but some reasonable options to known circumstances might include the following:

  1. Cultural norms differ in the location where the off-campus research will take place. 

PIs may wish to offer a “pre-departure” briefing for participants explaining cultural norms in the off-site location (physical or touching norms, verbal styles, etc.) PIs can offer alternatives to mitigate concerns arising from cultural differences  (e.g., offering to connect only in a group setting, or pairing participants so that there is less opportunity for misunderstanding.)  

  1. In advance of departure, PIs may wish to remind participants that they are personally available to listen to any concerns that participants may have about the off-campus research activity. 
  2. If the off-campus research site offers terrain, temperature, visual, auditory, or other challenges, offer to meet ahead of time with participants to discuss any special concerns they may have or accommodations they may need in order to fully participate.  
  3. The PI may wish to engage in regular “check-ins” privately with off-campus participants to ascertain whether there is anything that is impacting their full enjoyment about the off-campus research experience (physical or cultural barriers, behavior challenges, etc.) 
  4. Particularly in remote locations, physical circumstances may limit the ability for a participant to be separated from an individual alleged to have participated in misbehavior. Whenever possible, the participant and the individual allegedly engaging in misbehavior should be separated as completely as possible.  Consider assigning a “buddy” to a participant concerned of a possible recurrence, particularly when complete physical separation is not feasible.  

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