Research Compliance Fall 2019 Newsletter

Sponsor Requirements regarding Sexual Harassment


Effective October 22, 2018, the National Science Foundation (NSF) implemented a new award term and condition that requires grantee organizations to report findings of sexual harassment, or any other kind of harassment prohibited under university policy committed by a PI or co-PI. The award term and condition also requires the grantee to report the placement of the PI or co-PI on administrative leave relating to a harassment investigation.  These reports must be submitted within ten (10) business days of the date of the finding and the placement on administrative leave.

You can read the full notice and access FAQs here.


NIH has and continues to require grantees to notify it and obtain approval of all changes of key personnel, which can include sexual and other harassment results.  Recipients of NIH funding are required also to comply with applicable federal civil rights laws and regulations, as outlined in the NIH Grants Policy Statement (NIH GPS), as a term and condition of award:


In July 2019, NASA published a Federal Register notice requesting comments regarding proposed reporting requirements with respect to sexual harassment.  Similar to the NSF, the proposed regulation would require the grantee to report: (1) Any finding/determination that a PI or Co-I has committed sexual harassment; and/or (2) placement of the PI or any Co-I on administrative leave or any other administrative action related to a harassment investigation.

The deadline for public comment concerning NASA’s notice was August 16, 2019, so final guidance should be announced soon.

USC’s policy on Discrimination, Harassment, Sexual Harassment and Sexual Assault can be found here.

Foreign Influence and Research Security

NIH issued a statement on July 10, 2019 regarding their policies for disclosure of other support, foreign components, and financial conflicts of interest.  All NIH investigators and their staff should carefully review the notice as well as frequently asked questions published by NIH to ensure compliance with disclosure requirements.

Consistent with current procedures, other support and any associated updates should be submitted to NIH via the USC Department of Contracts and Grants (DCG).  Prior to an award being made, other support is reported using “Just In Time” procedures; after an award, the details must be disclosed in the annual research performance progress report (RPPR).  Please note that any substantive changes in project or budget, including identifying and adding a significant foreign component, require NIH prior approval.

USC’s Office of Research has published a memo regarding disclosure of other support here along with frequently asked questions, explaining the kinds of relationships requiring disclosure as well as general guidance on the scope of permissible outside activity under university policy.

New Research Integrity and Ethics Appointments

Effective July 1, 2019, Dr. Jeremy Goldbach became the IRB Director for social and behavioral research. Though Dr. Goldbach will focus on research taking place on the University Park Campus, his IRB will have broader scope encompassing social/behavioral research on both campuses.

Effective May 20, 2019, Dr. Kristen Grace (PhD/MD) became USC’s Research Integrity Officer (RIO).  In this new position, Dr. Grace leads USC’s efforts to elevate responsible conduct of research and scientific integrity.  Dr. Grace’s experience includes research ethics leadership positions at Cornell, University of Pennsylvania and the Office for Research Integrity.

FAQs on reporting Research Misconduct:

Should I Report Research Misconduct Allegations to my Department Chair?

Research misconduct allegations should be reported to the Research Integrity Officer (RIO).  If you are a department chair and have received allegations of research misconduct, promptly report those allegations to the Research Integrity Officer.  If you have already reported allegations to your department chair, also submit your allegations to USC’s Research Integrity Officer.

How Should I Report Other Allegations Related to Research?

The Office of Professionalism and Ethics maintains a hotline for filing reports or complaints.  Examples may include misuse of funds, sexual misconduct, lab safety, protection of research subjects, unmanaged conflicts of interest, and failure to follow intellectual property policy.

You may file such reports at the USC Report & Response.  You may also contact the Office of Research, the Office of Culture, Ethics and Compliance, or the Research Integrity Officer.

You can read more about the appointments here.

Download PDF copy of this newsletter!