For Grant Research with Federal Funds

To ensure compliance with regulations as research is conducted with federal funding (NSF, NIH, NEH, etc.), all investigators (i.e., principal investigators, project directors, and the like, as well as department chairs who oversee researchers in their departments) are asked to review these areas of compliance and to address the action items in each category

1) Misconduct in Science

Misconduct in science is “fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results.” Carleton’s policy applies to holders of federal grants and to students who participate in their research.


Please ensure that faculty doing research – especially holders of federal grants – are aware of the guidelines and procedures spelled out by the “Misconduct in Science” policy in the Carleton College Faculty Handbook.

2) FCOI (Financial Conflict Of Interest)

Though it is unlikely that Carleton investigators have any financial conflicts of interest, the federal government requires the College to annually document that either

  • investigators do not have financial conflicts of interest which affect their federally-funded research conflicts or
  • investigators who do have financial conflicts of interest have reported them to the College via the Office of the Provost (currently, Dean of the College Gretchen Hofmeister).

Carleton has adopted the federal government’s definition of financial conflicts of interest:

An investigator (project director/PD or principal investigator/PI) must disclose to the College all “significant financial interests” on his or her part and/or the part of his/her immediate family that include

  • at least $5,000 of payments from and/or equity interests in publicly-traded entities, or
  • any equity interest in non-publicly traded entities, or
  • reimbursed or sponsored travel such as a conference trip paid for by a corporate sponsor.

All interests related to a PD/PI’s institutional responsibilities, not just to an NIH (or other federal grant) project, must be disclosed to the College, with two exceptions:

  • Income from seminars, lectures, or teaching, and service on advisory or review panels for government agencies, institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with an institution of higher education.
  • Income from investment vehicles, such as mutual funds and retirement accounts, as long as the investigator does not directly control the investment decisions made in these vehicles.

Carleton’s FCOI full policy is available


All investigators with federal grant support must read Carleton’s FCOI policy (summarized below) and affirm their compliance by sending an email to Charlotte Whited (with an X on the appropriate line immediately below):

* I do NOT have any financial conflicts of interest________     

* I DO have a financial conflict of interest______

(If an FCOI, exists, please contact Gretchen Hofmeister in the Office of the Provost.)


Any PI/coPI with NIH funding must complete additional FCOI training (prior to engaging in research and at least every four years). Completing this NIH FCOI interactive training module satisfies the regulations: at the end, print the certificate of completion and route the certificate (in paper or digital version) to Charlotte Whited, mail code 1-GRANTS. 

3) RECR (Responsible and Ethical Conduct of Research)

Many federal grant making agencies – including the NSF and the NIH – require grantees to certify that they provide appropriate training and oversight in the Responsible and Ethical Conduct of Research (RECR).

To meet these requirements, Carleton utilizes CITI – Collaborative Institutional Training Initiative modules. Everyone involved in a federal grant – including but not limited to research trainees such as undergraduates, graduate students, and postdoctoral researchers – must complete this training. This online curriculum should be supplemented by in-person instruction on aspects of ethical research conduct appropriate to the specific project. In fact, the National Institutes of Health require such additional training of in-person instruction (see below). All PIs on federal grants are responsible for ensuring that students working with them have completed the online curriculum and have received face-to-face instruction.


Email Charlotte Whited ( with the names of your research students.


Each PI is to instruct their undergraduate researchers to complete the appropriate CITI modules before the end of June. Provide your students with the link to the Grant Office’s Responsible Conduct of Research page that provides step-by-step instructions to access the training modules.

Charlotte Whited will contact each PI in July with information regarding their students’ quiz results. If you have any questions, please contact Charlotte Whited, Associate Director of the Grants Office (x5833).