Posted: April 7, 2025

Dear faculty colleagues,

We are writing to share new training requirements from the National Science Foundation (NSF) and the Department of Energy (DOE). The CHIPS and Science Act requires all federal agencies to adopt requirements for financial assistance recipients to complete research security training.

DOE Requirement

Beginning on May 1, 2025, all DOE *Notices of Funding Opportunity (NOFOs) will include a requirement for all covered individuals to complete research security training in the 12 months immediately preceding the application date. Covered individuals from recipients or subrecipients who are added to an existing DOE award that includes the research security training requirement must complete the training within 30 calendar days of joining.

Covered individuals (a) contribute in a substantive, meaningful way to the development or execution of the scope of work on a project funded by or proposed to DOE, and (b) are designated as a covered individual by DOE. Minimally, DOE considers the following roles “covered individuals”: PI, project director (PD), co-PI, co-PD, project manager, and any others who, regardless of title, are functionally performing any of the preceding roles. DOE may expand the list of designated roles, and will specify in the applicable NOFO and/or terms and conditions of the award.

NSF Requirement

The NSF’s requirement will become effective with the implementation of the 2025 NSF Proposal and Award Policies and Procedures Guide (PAPPG). The 2025 PAPPG is expected to take effect in October 2025. The NSF will require that all individuals designated as senior/key personnel on a proposal complete research security training within one year of proposal submission. Individuals will certify in the Biographical Sketch and Current and Pending (Other) Support documents that they have completed training. We understand this to mean that the training must be completed prior to proposal submission.

Lehigh is in the process of updating its Responsible Conduct of Research Training Plan (i.e. policy) to include this requirement. We will share more information with you as that policy is drafted. In the meantime, because there is a time commitment involved in completing the training, we wanted to provide as much advanced notice as possible.

How to complete training

Lehigh will use the CITI Research Security training module in order to support compliance with the new requirements of both DOE and NSF. This module takes approximately one hour to complete. Please visit this page to learn more about completing your training and obtaining a certificate for your records. Instructions for adding this training to your CITI account can be found on the Vice Provost for Research website here.

We recognize and appreciate that these requirements mean that you will spend additional time on this task. However, it is essential in order to comply with our federal sponsors. Please contact Naomi Coll or Cynthia Kane with any questions or concerns.

Best regards,

Anand Jagota, Vice Provost for Research
Dominic Packer, Associate Vice Provost for Research
Cynthia Kane, Associate Vice Provost for Research and Sponsored Programs
Naomi Coll, Director of Research Policy and Compliance

 

*Will also be extended to financial assistance agreements resulting from those NOFOs, congressionally directed spending (CDS) projects, and non-competitive financial assistance agreements