I. PURPOSE
It is the goal of Touro University (“Touro”) to recognize the rapidly evolving landscape of artificial intelligence (“AI”) and its potential to advance knowledge, research, and scholarly work across disciplines. We support the responsible, ethical, and transparent use of AI tools to protect the integrity, safety, and originality of research while fostering innovation within our academic community.
As federal agencies, including the NIH, release updated guidance on AI use in research and grant submissions, Touro will provide regular updates and resources to ensure faculty, researchers, staff, and students remain compliant with federal, state, and institutional policies while responsibly leveraging AI capabilities in research.
Before starting any research project or grant submission that involves AI, researchers are strongly encouraged to discuss the appropriateness of using AI with co-investigators, collaborators, and field experts to ensure alignment with sponsor requirements, ethical standards, and institutional policies.
Through this policy, Touro affirms its commitment to supporting innovation while upholding the highest standards of academic integrity, compliance, and accountability in all research. It is the purpose of this policy to establish institution-wide standards for ethical, responsible, and transparent use of AI in all research, and grant writing, ensuring compliance with federal, state, and institutional requirements, including, without limitation, NIH Notice NOT-OD-25-132 (“Supporting Fairness and Originality in NIH Research Applications”), across all Touro University System campuses and locations.
II. POLICY
It is the policy of Touro that AI tools may be used in connection with research and grant writing only in limited circumstances and in accordance with the requirements set forth in this Policy. All researchers at Touro must complete the required training and provide attestation confirming their understanding of and compliance with Touro’s standards governing the appropriate use of AI in research.
- AI tools may be used for:
A. Grammar/spell checks.
B. Formatting references.
C. Basic graphics.
D. Activities permitted by sponsor requirements.
2. AI tools may not be used for:
A. Drafting application sections (Aims, Significance, Innovation, Approach).
B. Summarizing preliminary data narratives.
C. Conducting data analysis or generating outputs sufficient to replicate or substantially influence the analysis, unless permitted by sponsor requirements.
D. Generating, altering, or modifying images, figures, or visual data representations, unless permitted by sponsor requirements.
III. SCOPE
This policy applies to all faculty, researchers, staff, students, and contractors involved in any research, grant preparation, submission, or administration of research projects at Touro University (including its campuses in Illinois, Montana, New Mexico and New York), Touro University California, Touro University Nevada, Touro University Worldwide (including Touro College Los Angeles), New York Medical College, Hebrew Theological College, Lovelace Biomedical Research Institute, and Weissman Hood Institute at Touro.
IV. DEFINITIONS
- AI Tools means software/systems using machine learning, natural language processing, or generative models (e.g., ChatGPT, Gemini, Copilot) to generate, edit, or analyze content.
- Substantially AI-Developed Content means content where AI Tools contribute to ideation, drafting, or analysis beyond minor editing, formatting, or grammar checks.
V. PROCEDURES
- Attestation Requirement
A. All proposals submitted on/after September 25, 2025, must include a signed Principal Investigator (“PI”) attestation that:
a. No Substantially AI-Developed Content was included.
b. All content is the original work of the PI/team.
c. Any minor AI use is disclosed.
B. Digital signatures are acceptable if using authenticated platforms (Adobe Sign, DocuSign, Cayuse eSign). The attestation is usually part of the College Form or other internal routing form used in the initial preparation of a proposal or application.
- Training Requirement
A. Completion of CITI AI compliance training is mandatory for all individuals affiliated with research. This includes all research employees, PIs, and key personnel listed on any research proposals prior to submission. The mandatory trainings are as follows:
a. Artificial Intelligence (AI) and Human Subjects Protections (Webinar)
b. Artificial Intelligence: The Impact on Academic and Research Integrity (Webinar)
B. Training completion shall be tracked in the grants tracking portal and verified by Office of Research Administration (“ORA”)/Office of Sponsored Programs (“OSP”) before submission of any application.
- Exemptions & Deviations
A. Exemptions or deviations from this Policy may be granted only in limited and documented circumstances, where permitted by applicable sponsor requirements and where strict application is not practicable. The following steps must be followed to secure approved exemption and/or deviation:
a. All requests for exemption and/or deviation, including those based on sponsor-required AI use, must be submitted in writing and approved in advance of proposal submission by the ORA/OSP in conjunction with the Office of the Vice President for Research (OVPR).
b. Exemptions or deviations shall not, under any circumstances, permit misrepresentation of authorship or false attestations.
c. All approved exemptions or deviations shall be documented, retained in the official proposal record, and subject to audit or review.
- NIH Submission Cap
A. Pursuant to NIH Notice NOT-OD-25-132, NIH will accept only six new, renewal, resubmission, or revision applications from an individual Principal Investigator/Program Director or Multiple Principal Investigator for all council rounds in a calendar year (excluding T-series and R13 mechanisms).
B. ORA/OSP will monitor compliance with this cap through Cayuse/Grants Portal with automated flagging.
- Review of Proposals
A. ORA/OSP staff are responsible for reviewing proposals for the presence or use of generative AI content and ensuring that any AI use is appropriately disclosed, attributed, and aligned with sponsor policies.
B. This review responsibility includes monitoring for mandatory AI training, verifying authorship authenticity, maintaining research integrity, and addressing concerns around plagiarism and non-original content.
C. ORA/OSP staff will also support continued compliance for funded projects, particularly those involving data-generating AI systems, autonomous algorithms, or tools affecting research design and reproducibility.
- Monitoring and Enforcement
A. The PI must maintain for at least three years following the grant of any award:
a. PI Attestation forms.
b. AI usage disclosures.
c. All proposal drafts and logs of any compliance audits.
B. The OVPR will conduct random audits for compliance with this policy.
C. Potential violations may be reviewed or investigated by the OVPR and, where appropriate, escalated to the Research Integrity Officer in accordance with Touro’s Research Misconduct Policy.
a. Noncompliance with this Policy may result in administrative action, including withdrawal of a proposal prior to submission, corrective actions and/or institutional disciplinary measures.
b. Where required by law, regulation, or sponsor terms, instances of noncompliance may be reported to the NIH or other funding agencies.
VI. EFFECTIVE DATE
This policy is effective immediately.
VII. POLICY MANAGEMENT
Executive Stakeholder: Senior Vice President of Research
Oversight Office: Office of Research Administration/Office of Sponsored Programs
