Research Security
Similar to export control, research security is a form of national security. Since 2021, both the executive and legislative branches have issued regulatory measures to address growing global security concerns. The regulatory measures directly affecting universities are found in National Security Presidential Memorandum-33 (NSPM-33) and the CHIPS and Science Act (CHIPS). NSPM-33 requires all federal research funding agencies to strengthen and standardize disclosure requirements for Universities and researchers receiving federally funded awards. CHIPS requires:
- Researchers on federal research awards to complete annual research security training. (Section 10634)
- Researchers to certify at the time of proposal submission and annually during the duration of an award that they are not part of a malign foreign talent recruitment program. (Section 10632)
- Institutions to certify that researchers are aware of the prohibition of participating in malign foreign talent recruitment programs. (Section 10634)
Guidance on Specific Sponsor Research Security & Other Support Training Requirements
Within 2025, the federal government will begin requiring research security training of covered individuals prior to submitting proposals for federal awards. The Department of Energy (DOE) is the first agency to release their research security training requirement effective May 1, 2025.
*The United States Department of Agriculture (USDA) and National Science Foundation (NSF) have now joined the DOE in the research security training requirement. Learn more about the USDA's research security requirements. Learn more about NSF's research security policies.
Who: Covered Individuals - At a minimum, DOE designates as covered individuals any PI, PD, Co-PI, Co-PD, project manager and any individual regardless of title that is functionally performing as PI, PD, Co-PI, Co-PD or project manager. DOE may expand who qualifies as a covered individual in the Notice of Funding Opportunity(NOFO). See definition of Covered Individual here. Status as a consultant, graduate (master's or PhD) student, or postdoctoral associate does not automatically disqualify a person from being designated as a "covered individual".
What: Covered individuals must certify they have completed research security training within one year of application date. DOE interprets this as the 12 months immediately preceding the application date. Learn more about the DOE's Research Security Training Requirements for all R&D Financial Assistance Awards.
Who: All faculty and researchers identified as Senior/Key Personnel.
What: Effective October 1, 2025, NIH funded institutions must implement trainings on the requirements for the disclosure of other support to ensure Senior/Key Personnel full understand their responsibility to disclose all resources made available to the researcher in support of and/or related to their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institutions the researcher identifies for the current grant (NOT-OD-25-133). The Other Support training requirement may be satisfied by completing either the "Research Security Training (Combined Course)" or the CITI "Research Security Advanced Refresher" course.
Who: The term "covered individual" means an individual who -
- contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and
- is designated as a covered individual by the Federal research agency concerned.
CITI Research Security Training
Researchers have three research security training options through the online CITI Program:
- "Research Security Training (Combined Course)" - A condensed and combined single module course based on the NSF Research Security Training. The course is designed to meet the requirements of the CHIPS and Science Act and is recognized by federal agencies as compliant with their respective Research Security Training requirements. *Please note, this training should be taken in one sitting. CITI does not save progress as it does in other courses.
- "Research Security Training" - Comprehensive four module course supported by funding from NSF, NIH, DOE and DOD.
- "Research Security Advanced Refresher" - Provides foundational information and explores advanced research security topics.
Please see Compliance Education for research security and other compliance training information and links.
