Research Work Environment
Funding agencies are increasingly emphasizing the desire for research environments to be free of harassment, discrimination, and other inappropriate behaviors that are detrimental to the overall work environment. A 2018 National Academies report showed a strikingly high percentage of women (20%-50%) experience “sexually harassing behavior perpetrated by faculty/staff, and women students in academic medicine experience more frequent sexual harassment than those in science and engineering.” However, the issue goes beyond sexual harassment and can occur to anyone - this behavior includes, but is not limited to discrimination and other inappropriate conduct such as yelling, throwing objects, psychological bullying and intimidation, and engaging in personal relationships with someone who is in an inherently unequal position.
NIH
NIH expects that institutions have, “policies and practices in place that foster an environment free from harassment, including sexual harassment, discrimination, and other forms of inappropriate conduct that can result in a hostile work environment.”
There are a number of other NIH requirements related to promoting a positive work environment:
- Institutional Training Grant Letter
- Conference Safety Plan and Communication Strategy
- Institutional Reporting
Institutional Training Grant Letter
Per NIH NOT-OD-19-029, Institutional training grant applications (T15, T32, T34, T35, T36, T37, T90/R90, TL1, TL4) must include a letter that describes the institutional commitment to ensuring that proper policies, procedures, and oversight are in place to prevent discriminatory harassment and other discriminatory practices. This letter should be included with other Letters of Support on the PHS 398 Research Training Program Plan form. Duke provides the following letter to be incorporated into training grant applications:
Conference Safety Plan and Communication Strategy
Per NIH NOT-OD-22-074, applicants for NIH Support for Conferences and Scientific Meetings (R13/U13) must include a Plan to Promote Safe Environments (“Safety Plan”) as part of Just-In-Time materials should the application be recommended for funding. Duke has prepared a Safety Plan document that includes all required elements to comply with the NIH policy. If the conference will take place off Duke premises, please contact Lindsey.Spangler@duke.edu to review alternate reporting options based on the location of the conference.
In addition to the Safety Plan at just-in-time, R13/U13 applicants must also describe the strategy that will be used to communicate the Safety Plan to conference attendees and a plan to document allegations and resulting actions. Applicants must also provide information on the steps the organizers will take to ensure a safe and respectful environment for all attendees, free from discrimination and harassment. Duke has prepared a template that applicants can modify based on their preference for communication: Communication Strategy for R13 and U13
Reporting Requirements
Per NOT-OD-22-129, Institutions are required to notify NIH when a Program Director or Principal Investigator or other Senior/Key personnel on an NIH grant or cooperative agreement notice of award is removed or otherwise disciplined due to concerns about harassment, bullying, retaliation, or hostile working conditions. Additionally, per NIH GPS 8.1.2.6 and 8.1.2.7, institutions must mention whether changes in recipient institution, PD/PI, or Senior/Key personnel are related to concerns about safety and/or work environments.
NIH’s website on Supporting a Safe and Respectful Workplace includes additional details related to this reporting including NIH’s intake process as well as definitions and FAQs.
NSF
NSF has taken a number of steps as noted in “Important Notice No. 144” to ensure all NSF-funded research and learning environments (including at field sites) is free from sexual harassment and other forms of harassment.
Safe and Inclusive Work Environments Plan
NSF’s Proposal & Award Policies & Procedures Guide (PAPPG), Section II.E.9 requires applicants (via the Administrative Organizational Official, “AOR”) to certify that they have a project-specific plan for creating and maintaining a Safe and Inclusive Work Environment if they propose to conduct research off-campus or off-site. NSF defines off-campus or off-site research as, “data/information/samples being collected off-campus or off-site, such as fieldwork and research activities on vessels and aircraft.”
Duke created a template that can be used as a foundation for complying with this requirement. Please note that the specific NSF solicitation will state whether the Safe and Inclusive Work Environments Plan must be included with the proposal. If not required at submission, please complete this Plan template and have on file if requested by NSF. The NSF Biological Sciences (BIO) and Geological Sciences (GEO) directorates are in a pilot phase of requiring Plan submission for certain solicitations. Please review your solicitation carefully to determine whether submission of the plan is required. The PI is responsible for ensuring that any individuals working off-site receive a copy of this Plan prior to beginning their work on the project.
Conference, Symposia, and Workshop Proposal Code of Conduct
While not required to be submitted in the proposal package for review, conference proposals to NSF, including symposia and workshop proposals, are required to have a policy or code of conduct that addresses sexual harassment, other forms of harassment, and sexual assault and must include clear and accessible means of reporting violations of the policy or code of conduct. Additionally, the policy or code of conduct must address the method for making a complaint as well as how any complaints received during the conference will be resolved. The policy or code of conduct must be disseminated to conference participants prior to attendance at the conference as well as made available at the conference itself. Below is a template that can be used to comply with this requirement:
Reporting Requirements
NSF’s terms and conditions include a requirement for institutions to notify NSF of:
- Any finding/determination regarding the PI or any co-PI that demonstrates a violation of awardee policies or codes of conduct, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault; and/or
- if the PI or any co-PI is placed on administrative leave or if any administrative action has been imposed on the PI or any co-PI by the awardee relating to any finding/determination or an investigation of an alleged violation of awardee policies or codes of conduct, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault.
This notification must be submitted by the Authorized Organizational Representative (AOR) within ten business days from the date of the finding/determination OR the date of the placement of a PI or co-PI by the awardee on administrative leave or the imposition of an administrative action, whichever is sooner.
NSF has additional information on this Term and Condition on their website, including the full Federal Register Notice and FAQs.
DOE
Promoting Inclusive and Equitable Research (PIER) Plans
As of October 21, 2022 the Department of Energy Office of Science requires all applicants to submit a PIER Plan as an appendix the to proposal narrative. The PIER Plan should “describe the activities and strategies applicants will incorporate to promote diversity, equity, inclusion, and accessibility in their research projects.” The Plans will be reviewed as part of the merit review process and will be used to inform funding decisions. Plans should be limited to three pages and should NOT be a re-statement of standard institutional policies or broad principles, thus, Duke University has prepared a template that should be tailored to an individual project.
DOE’s PIER Plan Website includes additional information such as Things to Consider When Developing a PIER Plan and FAQs.
NASA
Reporting Requirements
NASA’s terms and conditions include a requirement for institutions to notify NASA of:
- Any finding/determination regarding the PI or any Co-I that demonstrates a violation of the recipient's policies or codes of conduct, relating to sexual harassment, other forms of harassment, or sexual assault; and/or
- if the PI or any Co-I is placed on administrative leave or if any administrative action has been imposed on the PI or any Co-I by the recipient relating to any finding/determination or an investigation of an alleged violation of the recipient's policies or codes of conduct, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault.
This notification must be submitted by the Authorized Organizational Representative (AOR) within ten business days from the date of the finding/determination OR the date of the placement of a PI or co-PI by the awardee on administrative leave or the imposition of an administrative action.
Additional details regarding NASA’s reporting requirement can be found in the Federal Register.
Non-federal sponsors
- Simons Foundation
- American Heart Association (AHA)
- See award terms and conditions regarding unlawful harassment or discrimination
- Robert Wood Johnson Foundation (RWJF)
- See award terms and conditions regarding sexual harassment, other harassment, discrimination, hostile work environment, financial impropriety, academic integrity, and breach of fiduciary obligations
- Howard Hughes Medical Institute (HHMI)
- See award terms and conditions regarding misconduct and unlawful harassment or discrimination
- Burroughs Wellcome Fund (BWF)
- See award terms and conditions regarding falsification and plagiarism, fraud and theft, willful or negligent acts, unlawfulness, failure to adhere to ethical standards, financial mismanagement, loss of certification, and sexual harassment or discrimination
- National Geographic Society (NGS)
- See award terms and conditions regarding harassment and discrimination, and violations of anti-bribery and corruption laws
- International Initiative for Impact Evaluation (3ie)
- See award terms and conditions regarding unlawful sexual exploitation, abuse, and harassment