Comment Letter

COGR Submits Letter to ORI on RFI on Research Integrity (85 FR 66341)

The Council on Governmental Relations (COGR), representing 190 U.S. research universities and affiliated institutes, responded to the Office of Research Integrity's (ORI) request for information regarding fostering a climate of research integrity through training and education. COGR acknowledges the critical role of Responsible Conduct of Research (RI/RCR) education in promoting ethical research and compliance with NIH requirements, but identifies several persistent challenges faced by institutions: tailoring RI/RCR programs to diverse disciplines and career stages, securing engagement from senior investigators, and ensuring training content and modalities remain relevant and effective amid evolving research practices.

To address these challenges, COGR highlights the need for both discipline- and career stage-specific educational materials, noting that most available resources do not adequately meet these criteria and often require significant funding and effort to develop. The organization also underscores difficulties in eliciting buy-in from established researchers, for whom existing training may seem administrative rather than substantive. Additionally, COGR points to the tension between the efficiency and accessibility of online training—particularly prominent during the COVID-19 pandemic—and NIH's preference for in-person instruction. The letter advocates for ORI assistance in developing targeted resources, updating training content to reflect modern research practices such as big data and multi-site collaborations, and supporting research into the efficacy of diverse training modalities to inform evidence-based education strategies. COGR expresses appreciation for ORI’s engagement and willingness to collaborate on advancing best practices in research integrity training.

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