NSF’s new PAPPG (Proposal & Award Policies & Procedures Guide), effective for proposals with off-campus or off-site work due on or after January 30, 2023, requires proposers to certify that they have a plan for creating and maintaining Safe and Inclusive Working Environments for Off-Campus and Off-Site Research for that project.
INSTRUCTIONS FOR NSF PRINCIPAL INVESTIGATORS
1. Determine whether any “off-campus or off-site research” will occur on their NSF-funded award (see definition below). Plans are only required for NSF-funded awards containing research that is conducted off-site or off-campus.
2. Complete the project specific information document and;
3. Attach it to your UI Routing Form.
4. Distribute the project specific information document (“the plan”) to everyone who will participate in an off-campus or off-site research activity prior to those individuals leaving campus to engage in the off-site or off-campus research.
5. Retain documentation of who received the plan (email or signup sheet is sufficient) and the plan itself in their personal grant files or in the departmental grant file.
IMPORTANT: The plan should not be submitted to NSF unless 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.
Definition: 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.”
UNIVERSITY OF IOWA POLICIES AND EXPECTATIONS FOR ENSURING A SAFE AND INCLUSIVE WORK ENVIRONMENT
The University of Iowa is committed to addressing harassment and fostering a safe and healthy work environment. 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 study at an off-site location.
In addition, it is NSF policy to “foster safe and harassment-free environments whenever science is conducted.” (NSF 2023 PAPPG Guide II-E.9]. Grantees are required, effective with proposals submitted 1/30/23 or later, to certify that we have a plan in place that addresses:
- Abuse of any person, including but not limited to harassment, stalking, bullying or hazing or any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; and
- Conduct that is unwelcome, offensive, indecent, obscene, or disorderly
The University meets NSF requirements (as well as its own expectations) by using the policies and procedures outlined below, and as further amplified to cover special circumstances as dictated by the PI in the project-specific information shown in this document. Principal Investigators are responsible for distributing a copy of this plan to each participant in an off-campus or off-site research prior to those individuals leaving campus to participate in the off-campus or off-site activities.
KEY POLICIES AND PROCEDURES
In addition, the University of Iowa has a robust policy system designed to enforce the expectations for a safe and healthy work environment. The following is a list of applicable Board of Regents and Administrative (Institutional) policies. Note that the hyperlinks are publicly accessible and easy to view.
- II-3, Human Rights
- II-4, Sexual Harassment and Sexual Misconduct
- II-5, Consensual Relationships Involving Students
- II-6, Nondiscrimination Statement
- II-7, Disability Protection Policy and Accessibility Statement
- II-8, Affirmative Action and Equal Employment Opportunity, Statement of Policy and Purpose; Statement on Diversity
- Chapter 9 – Firearms and Other Weapons on Campus
- Chapter 10 – Violence
- Chapter 11 – Anti-Retaliation
- Chapter 14 – Anti Harassment
Iowa Board of Regents Policies
Chapter 2: Operations
- 2.1.4 Human Resources/Policies
- L. Grievance Investigations
- M. Harassment
Chapter 3: Academic Policies and Procedures
Chapter 4: Regent Institutions
FREQUENTLY ASKED QUESTIONS
QUESTION 1: What does “off-campus” or “off-site” mean. If I’m housed in a leased building adjacent to a UIN campus, does this new requirement apply to me?
Answer: The intent of this requirement is to provide guidance and protection for participants when they do not have ready access to the on-campus in-person resources they normally do. If your participants continue to have such access, no plan 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 would apply only to that research component.
QUESTION 3: I forgot to send a plan to one or more participants before we left; what do I do now?
Answer: If the off-site research is still taking place, send the plan now to the participant(s). If the off-site research is over, send an email to DSP explaining the circumstances. DSP staff 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: It includes all UI 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.) UI’s plan may be shared and adapted for use by the subrecipient. Typically, a UI PI will only assume responsibility for UI participants but there may be cases where guests or participants from other entities may need to use UI’s plan. This is allowed, but places a special administrative burden on the UI PI as these participants will not already be familiar with UI policies or practices, and special coordination across entities may be needed. It is a good idea to confer with DSP well in advance of the off-site research should this be applicable so that special arrangements can be created.
QUESTION 5: Is it possible to name a backup point of contact listed on the form?
Answer: Yes, in fact it is advisable to have a primary and a secondary point of contact available. The Principal Investigator must be listed on the form 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. Make sure and include the cell phone and email of the alternative contact.
QUESTION 6: What should happen if the person doing the alleged concerning conduct 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 conduct 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:
- 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.)
- 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.
- 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 arrangements they may need in order to fully participate.
- 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.)
- 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.
- There is only a single satellite phone (or equivalent) available for contact outside the group. Consider having a second phone available and controlled by a different individual, or ask someone from another group or from the entity being visited if participants can also approach them should need arise for a confidential call to be placed. Notify participants accordingly.