NSF's Safe and Inclusive Environment FAQs

ANSWER: 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 and research activities on vessels and aircraft.”  

Projects that include site visits, fieldwork, or other research activities that take place off campus will need a plan.  When deciding whether a project includes off-campus or off-site components, please consider the following guidance:

The intent of this requirement is to provide guidance and protection for participants when they may not have ready access to the on-campus resources they normally do. If your participants continue to have such access i.e., project is in a MSU leased building near campus or on MSU Clery Geography, a plan may not be needed. For example, work at the Kellogg Biological Station is part of MSU Clery Geography and would not require an NSF project plan. 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.

If you are using the off-campus F&A rate, you likely have "off-campus or off-site research" that would necessitate a plan. 

It is appropriate to consciously consider the options for access to campus resources by location and to be able to provide documentation or justification if questions on resource access are raised. 

ANSWER: NSF’s and MSU’s policies are applicable to all NSF funded projects led by MSU PIs regardless of the performance site of the research. For off-campus or off-site research, however, NSF requires that a plan be in place to address certain behaviors should they occur off-campus. As mentioned above, the intent of this requirement is to provide guidance and protection for participants when they may not have ready access to the on-campus resources they normally do.

It is NSF policy (NSF 23-1) to foster safe and harassment-free environments wherever science is conducted.  At MSU, the policy prohibiting sexual harassment and assault is the Relationship Violence and Sexual Misconduct and Title IX Policy. The policy prohibiting other forms of discrimination and harassment is the Anti-Discrimination Policy.  Questions about MSU’s non-discrimination and anti-harassment policies may be referred to MSU’s Office for Civil Rights and Title IX Education and Compliance. 

ANSWER: Send the plan now to the participant(s) explaining the circumstances and retain all documentation within your grant file or in the departmental grant file. NSF has not identified what corrective actions should be taken in these cases, but it may be advisable to have an uninvolved third party check with the participant to ascertain whether there were any issues that arose while off-campus that made the participant feel unsafe or needed reporting.

ANSWER: It includes all MSU 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). MSU’s plan may be shared and adapted for use by the subrecipient. Typically, a MSU PI will only assume responsibility for MSU participants, but there may be cases where guests or participants from other entities may need to use MSU’s plan. This is allowed, but places a special administrative burden on the MSU PI, as these participants will not already be familiar with MSU policies or practices, and special coordination across entities may be needed. It is a good idea to confer with the PI of the subrecipient organization well in advance of the off-site research should this be applicable so that special arrangements can be included in the plan. 

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” field 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. Be sure to include the phone number and email address of the alternative 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 misconduct 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 person on the off-campus team (whether or not from MSU) to assist them in appropriate next steps.

ANSWER: PIs may devise options they believe are appropriate to the circumstances, but some reasonable options to known circumstances might include the following:

1. 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.)

2. 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 accommodations they may need to fully participate. 

3. The PI may wish to engage in regular “check-ins” with 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.)

4. 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 discussing possible mitigation strategies with a participant concerned of a possible recurrence, particularly when complete physical separation is not feasible. 

5. There is only a single satellite phone (or equivalent) available for contact outside the group.  Consider including a second phone in your project budget.  Both phones should be made available to all participants, and they should be controlled by different individuals.  You might also consider asking someone from another group or from the entity being visited if participants can approach them should the need arise for a confidential call to be placed.  Notify participants accordingly.

ANSWER: No. The subaward would not be considered an off-site/remote location for MSU unless the MSU participants would be going to the subaward location to perform research activities.

That being said, the subrecipient may have research activities within their scope of work that would be considered off-site/remote. In these scenarios, we would anticipate that the subrecipient would follow their institutions procedures for developing a plan. On MSU's Subrecipient Commitment Form, a new project related question has been added to address this scenario.

On the NSF Cover Sheet within the proposal, the question for off-site/remote locations should be checked if either MSU or the subrecipient has indicated off-site/remote work.

ANSWER: Typically, no. The requirement concerns research activities that are being performed off-site/remotely, rather than to the dissemination of research. If, however, research activities are being performed while at the conference, and the conference is off-site/remote, it could be applicable.

NSF has a separate requirement (see Chapter II.D.7 of the PAPPG) that requires proposers requesting NSF funds for a conference, symposia, or workshop to have a policy or code of conduct in place that addresses certain types of prohibited conduct and that includes clear and accessible means of reporting violations of the policy or code of conduct (see this page for more information).