Safe and Inclusive Working Environment

NSF Safe and Inclusive Work Environment Plan Requirements for Off-Campus Research

It is NSF policy (NSF PAPPG, Chapter XI.A.1.g.) to foster safe and harassment-free environments wherever science is conducted. NSF’s policy recognizes that a community effort is essential to eliminate sexual and other forms of harassment in science and to build inclusive scientific climates where people can learn, grow, and thrive.

For proposals submitted on or after January 30, 2023, grantees are required to certify that we have a plan in place for each project with off-campus or off-site research that addresses:

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
Conduct that is unwelcome, offensive, indecent, obscene, or disorderly.

Some solicitations from Biological (BIO), Geosciences (GEO), and the Office of International Science and Engineering (OISE) directorates will pilot requiring the submission of a Safe and Inclusive Work Environment Plan. This Plan is a two-page supplementary document that will be considered as part of the Broader Impacts criteria during the review process. It must address:

a brief description of the field setting and unique challenges for the team;
the steps the proposing organization will take to nurture an inclusive off-campus or off-site working environment, including processes to establish shared team definitions of roles, responsibilities, and culture, e.g., codes of conduct, trainings, mentor/mentee mechanisms and field support that might include regular check-ins, and/or developmental events; 
communication processes within the off-site team and to the organization(s) that minimize singular points within the communication pathway (e.g., there should not be a single person overseeing access to a single satellite phone); and 
the organizational mechanisms that will be used for reporting, responding to, and resolving issues of harassment if they arise.

NSF grant reviewers will evaluate plans on the following:

Is there a compelling plan (including procedures, trainings, and communication processes) to establish, nurture, and maintain inclusive off-campus or off-site working environment(s)?
Does the proposed plan identify and adequately address the unique challenges for the team and the specific off-campus or off-site setting(s)?
Are the organizational mechanisms to be used for reporting, responding to, and resolving issues of harassment, should they occur, clearly outlined?

UCCS Plan Requirements

For each National Science Foundation (NSF) proposal that includes research off-campus or offsite, there must be a plan in place for that proposal that describes how certain behaviors (details below) will be addressed as well as the plan to ensure a safe and inclusive work environment.

UCCS requires that this plan be:

Developed by the PI using UCCS’s Safe & Inclusive Working Environment for Off-Campus or Off-Site Research Plan template and saved by the PI at the proposal stage;
Provided to the Office of Sponsored Programs (OSP) before the NSF award is setup;
Implemented and retained by the PI; and
Distributed by the PI to each participant in an off-campus or off-site research prior to departure or involvement in the off-campus activity.

(Reference: NSF Proposal and Award Policies Procedures Guide (PAPPG) 23-1 Chapter II. E.9.)

If a NSF directorate requires the plan as part of the proposal documents, PIs are recommended to use the above UCCS template, but do not need to provide the plan to OSP separate from the proposal.

IMPORTANT: The PI will also need to ensure that they check the Checkbox on the Proposal Cover Page that the project is proposing Off-Campus/Off-Site research, regardless of whether the award notification requires that a plan be submitted to NSF.

Subaward and Collaborative Proposals

If UCCS is a subaward recipient on an NSF-funded project with off-campus/off-site research, UCCS does not require the UCCS PI to complete a plan. Instead, UCCS will rely on lead institution to provide and implement the plan.

For Collaborative Proposals, if a Safe and Inclusive Working Environment Plan is required to be submitted with the proposal, the lead institution should submit one plan for all off-campus/off-site research. If a plan is not required to be submitted with the proposal, each institution is responsible for their own plan with regard to any off-campus or off-site performances their organization is facilitating.

What is Off-Campus or Off-Site Research?

For the purposes of this NSF requirement, 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 (PAPPG, Chapter 2: D. 2. a. Proposal Contents). UCCS further defines off-campus or off-site research for this requirement with the following:

Data/information/samples being collected off-campus or off-site, including at UCCS owned locations away from main campus, for more than three consecutive days;
Data/information/samples being collected off-campus or off-site by any project team member, including team members from subrecipient organizations performing research outside their primary place of performance;

Off-campus or off-site research is NOT:

Meetings and conferences that do not include collecting data/information/samples;
Data/information/samples collected by subrecipients or collaborative organizations at their primary place of performance;
Research consisting exclusively of electronic surveys or use of online platforms such as Teams;
Research performed in a "work-from-home" setting by an individual.

If you have questions about whether your NSF proposal includes off-campus or off-site research, please reach out to composp@uccs.edu. When in doubt, create a plan.

Harassment Reporting Requirements

The University of Colorado Colorado Springs (UCCS) is committed to maintaining an environment free from sexual misconduct, discrimination or harassment based on race, color, national origin, sex, pregnancy, age, marital status, disability, creed, religion, sexual orientation, gender identity, gender expression, veteran status, political affiliation, or political philosophy.

Sponsors often have additional expectations and reporting requirements when harassment and other prohibited conduct has occurred on funded projects. This section summarizes the requirements for some of these sponsors. Please visit individual Sponsor's websites and carefully read grant solicitations to ensure you are familiar with specific requirements and expectations.

Harassment of any kind is never acceptable, whether or not a project is funded, and OSPRI encourages individuals to report any such behavior through any of the reporting channels available. Learn more about OIE's Reporting Options.

National Science Foundation (NSF)

In 2018, NSF issued a Notice updating their terms and conditions regarding sexual harassment, other forms of harassment, and sexual assault. In addition to outlining their expectations regarding behavior, NSF requires awardees to notify NSF of:

any findings/determinations regarding the PI or co-PIs demonstrating violations of awardee policies or codes of conducts, statutes, or regulations 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 actions have been imposed on the PI or any Co-PI by the recipient relating to any finding/determination or investigation of such violations.

NSF requires notification to be submitted within 10 business days of the finding/determination or the date of the placement of a PI or Co-PI on administrative leave or other administrative action, whichever is sooner.

NSF has created a page summarizing these terms and conditions, on which links to FAQs and reporting forms can be accessed.

OSPRI works with campus OIE to determine when report from the institution is required.

National Institutes of Health (NIH)

NIH requires that organizations receiving NIH funds:

have systems, policies, and procedures in place to manage research activities in accordance with their standards and requirements
comply with federal laws, regulations, and policies protecting the rights and safety of individuals working on NIH-funded projects.

In 2022, they published NOT-OD-22-129 outlining institutional requirements for notifying the NIH within 30 days of the removal or disciplinary action against PD/PIs and other senior or key personnel due to concerns about harassment, bullying, retaliation, or hostile working conditions.

Additionally, NIH requires recipients of conference grants ("R13 or U13") funding to submit a "safety plan" ensuring policies, procedures, and oversight are in place to prevent discriminatory harassment and discriminatory practices (NOT-OD-22-074). As part of this plan, funding recipients must detail how violations and complaints can be reported to the appropriate authorities, including how to report to the HHS Office for Civil Rights and NIH directly.

NIH summarizes its commitment and policies to safe, respectful, harassment-free work environments for NIH-funded activities on its "Supporting a Safe and Respectful Workplace" webpage. The page also offers a variety of useful NIH-specific and general information on fostering such an environment as well as links to dedicated reporting web form and a detailed FAQ.

OSPRI works with campus OIE to determine when report from the institution is required.

Department of Energy (DOE)

The Department of Energy (DOE) requires institutions to ensure that "scientists, engineers, students, support staff, and others participating in research and development activities funded under DOE financial assistance awards must be able to perform their work without unnecessary barriers." Such barriers include discrimination or other behaviors prohibited by law, including harassment (sexual or non-sexual).

Currently, the DOE requires recipients of DOE grants or cooperative agreements to notify their DOE contracting officer whenever:

a PI or approved project director must be absent for more than three months, or
when there is a 25 percent reduction in time devoted to a project for any reason including administrative leave.

While this reporting requirement applies in any circumstance, including allegations or findings of harassment, the DOE is currently engaging in discussions on developing reporting policies specifically for that purpose, similar to those of the NSF.

The DOE's Office of Scientific Workforce Diversity, Equity, and Inclusion (SW-DEI) website includes guidance regarding their policies as well as links for reporting instances of discrimination or harassment occurring at institutions receiving DOE funding or where DOE funded activities are being carried out.

OSPRI works with campus OIE to determine when report from the institution is required.

National Aeronautics and Space Administration (NASA)

In March 2020, NASA issued Notice 20-029 detailing their harassment policy and reporting requirements. NASA regularly publishes their updated behavioral expectations and reporting requirements in their Grants and Cooperative Agreement Manual. Additionally, they require that these Terms and Conditions regarding harassment and harassment reporting are included in the all subawards/subcontracts. (Mirror NSF Requirements)

According to NASA's Terms and Conditions, funding recipients are required to report to NASA:

any finding/determination regarding the PI or co-I(s) demonstrating a violation of the recipient's policies or codes of conduct relating to sexual or other forms of harassment or sexual assault, and/or
if any PI or Co-I(s) are placed on administrative leave or other administrative action is imposed related to such findings/determinations or allegations of violations.

OSPRI works with campus OIE to determine when report from the institution is required.

National Oceanic and Atmospheric Administration (NOAA)

NOAA 202-116 - NOAA Sexual Assault and Sexual Harassment Prevention and Response Policy

Research Corporation for Science Advancement (RSCA)

Any awards issued after 2/1/2023 from the Research Corporation for Science and Advancement (RCSA) require promptly reporting any determination by the Institution that a PI or Co-PI has violated the Institution's policies or any applicable laws regarding sexual harassment, or other forms of harassment. Institutions will promptly, upon determination of the violation, report to RCSA as directed in the applicable Notice of Award.

White House Inventory of Sexual Harassment Policies at Science Agencies

2/26/24: White House Publishes Inventory of Sexual Harassment Policies at Science Agencies (FYI Science Policy News, AIP) - The White House published an inventory this month of federal science agency policies, procedures, and resources relating to sex-based and sexual harassment involving extramural research awardees. The inventory, which includes public-facing and internal documents, was created by the Inter-agency Working Group on Safe and Inclusive STEM Environments — a group that was established by the White House Office of Science and Technology Policy in response to the CHIPS and Science Act of 2022 to coordinate agency efforts to combat harassment in research.