NSFNIHDept. of Energy (DOE)USDA
Research Security & Other Training RequirementsEffective Oct. 10, 2025. Sr./Key Personnel must certify they completed research security training that meets requirements of Important Notice 149 within 12 months prior to proposal submission. AOR must certify that Sr./Key Personnel have completed the research security training requirement. Condensed research security training module developed with NSF support will satisfy training requirements.

Effective Oct. 1, 2025, NIH recipients must provide training to all Sr./Key Personnel on the requirement to disclose all research activities and affiliations (active and pending) in Other Support. This requirement "adds to the current policy" under Sec. 2.5.1 Just-in-Time Procedures, which specifies requirement to provide disclosure of Other Support at JIT.  Institutions must also have a written and enforced policy on requirements for Sr./Key Personnel to disclose Other Support.

Each covered individual (for NIH this is defined as senior/key personnel) listed on an NIH grant application must certify that they have completed RST within 12 months of the date of application submission. NIH will collect the individual certification at the time of the application submission, through the Biographical Sketch in SciENcv.

Applicant institutions must certify that each covered individual who is employed by the institution and listed on the application has completed RST. The Authorized Organization Representative (AOR), via their signature on the face page of the application, will certify the applicant institution’s compliance with this requirement.

Completion of RST and the individual and institutional certifications will be effective for applications submitted for due dates on or after May 25, 2026.

FAL 2025-02 sets forth the research security training requirements for all R&D Financial Assistance Awards. Research security training is required for all Covered Individuals. Applicant must certify that each Covered Individual employed by applicant and listed on the application has completed a research security training program that meets the requirement of Sec. 10634 of CHIPS Act. NSF research security training modules may be used, but are not mandatory. Covered Individuals are designated by DOE in the NOFO per one of the following Options detailed under the row labeled "What individuals are covered?" Requirement goes into effect May 1, 2025.  
Training for covered individuals on application must be completed in the 12 months preceding the application date. Individuals and institutions must certify to completion of this training. New Covered Individuals added to a project must complete the training within the 30 days before joining the project. Recipients must maintain records documenting compliance with this requirement. Covered Individuals previously identified by recipient who have already certified completion of the research security training do not need to complete it again even if submitting an updated Current and Pending Support form during the life of the award. 
Applicant must certify they have competed research security training not more than one year prior to date of application, and recertify annually for duration of award. Entity employing applicant must certify applicant has completed research security training. 

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