Federal Research Security Training

Requirement for Research Security Training is effective May 1, 2025

Per the DOE's October 7, 2024 Financial Assistance Letter:

Covered individuals must certify that they have “completed within one year of such application research security training that meets the guidelines.” DOE interprets this as the 12 months immediately preceding the application date. Prime applicants must “certify that each covered individual who is employed by such institution or organization and listed on the application has completed such training.” DOE interprets this as the prime applicant’s responsibility to verify the accurateness of the individual certifications as a condition of submitting an application to DOE.

This applies to all DOE and NNSA notice of funding opportunities (NOFOs), financial assistance agreements, congressionally directed spending (CDS) projects, and non-competitive financial assistance agreements that are: 1) issued on or after the effective date of this FAL; and 2) encompass research and development (R&D) activities, or technical assistance to support R&D activities.

Submission of proposal or acceptance of award indicates agreement to accept this training requirement.

Requirement for Research Security Training is effective December 31, 2025

Per the NSF's July 10, 2025 Important Notice No. 149:

Research Security Training Requirement for Federal Award Personnel: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234), each individual identified as a senior/key person must certify that they have completed the requisite research security training that meets the requirements specified in Item 2 of Important Notice No. 149 within 12 months prior to proposal submission.

Certification Regarding Research Security Training for Federal Research Award Personnel: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234), the Authorized Organizational Representative (AOR) must certify that all individuals identified as senior/key personnel have completed the requisite research security training that meets the requirements specified in Item 2 of Important Notice No. 149 within 12 months prior to proposal submission.

Responsible and Ethical Conduct of Research (RECR)/Responsible Conduct of Research (RCR)- we are required to provide this training to undergrad students, graduate students, postdoctoral faculty, and other senior/key personnel who will be supported by NSF to conduct research.[1] Can be taken online and is required every four years.

 [1] This is an additional requirement for NSF to the RST.

All covered individuals, as defined by the Agency, certify that they have completed research security training within one year prior to application submission, and applicant entities must certify that covered individuals employed by the entity have taken such training. [1]

 
[1]A covered individual is any Principal Investigator (PI) (regardless of level of effort), any CoPI (regardless of level of effort), and only Co-Investigators (Co-I) proposing to spend ten percent or more of their time in any given year on a NASA-funded award. Covered individuals named on a NASA grant or cooperative agreement proposal must certify that they have satisfied the training requirement described below by signing a certification on the NASA biographical sketch and current and pending (other) support forms.

Required effective August 5, 2026 - All covered individuals, as defined by the Agency, certify that they have completed research security training within one year prior to application submission, and applicant entities must certify that covered individuals employed by the entity have taken such training. [1]

 
[1]A covered individual is any Principal Investigator (PI) (regardless of level of effort), any CoPI (regardless of level of effort), and only Co-Investigators (Co-I) proposing to spend ten percent or more of their time in any given year on a NASA-funded award. Covered individuals named on a NASA grant or cooperative agreement proposal must certify that they have satisfied the training requirement described below by signing a certification on the NASA biographical sketch and current and pending (other) support forms.

Requires RST training for all covered individuals on a project by project basis.[1] A DoW-wide timeline is still pending for October 2026, but the CHIPS and Science Act requires that covered individuals complete RST within 12 months prior to proposal submission, and prior to addition of new personnel to ongoing projects.
 

[1] A covered individual at an extramural research institution who, as designated by the extramural research institution, contributes significantly to the design or execution of an R&D project that is funded, in whole or in part, by the DoW, and who is considered essential to the successful performance of the R&D project. Covered Individuals include those listed as key personnel in proposals for DoW R&D project proposals (e.g., the principal investigator or co-principal investigator). 

Requirement dates for Research Security Training are dependent upon the award
Per the USDA's July 8, 2025 AMERICA FIRST MEMORANDUM FOR USDA ARRANGEMENTS AND RESEARCH SECURITY:

As a term and condition of entering into an arrangement with USDA related to research and development (R&D) or science and technology (S&T), applicants must certify that research security training has been completed not more than one year prior to the date of application and must recertify annually for the duration of the award.