Federal Research Security Requirements

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Federal Research Security Requirements

(As of August 1, 2025)
This page will continue to be updated as we receive more information.

In accordance with the the federal government is strengthening safeguards to protect research from foreign influence, cybersecurity threats, and others risks. As part of this effort, federal sponsors have begun implementing Research Security requirements for all "covered individuals" who contribute substantively to federal research projects.

Federal sponsors define "covered individuals" as senior/key personnel on a sponsored project. These requirements can include:

Completion of Research Security Training
Maintaining an ORCID iD
Certifying or disclosing that "covered individuals" are not participating in Malign Foreign Talent Recruitment Programs (MFTRP)

To meet the MFTRP requirement, �� now requires all key personnel submitting proposals to attest in Novelution that they are not participating in a MFTRP. This attestation is mandatory for each key person, regardless of the funding source.

The below information includes guidance, definitions, and requirements which may vary by sponsor.

If a sponsor is not listed, it does not mean they do not have a requirement, please refer to sponsor solicitation or guidelines.

Definitions & Requirements by Sponsor

Department of Energy (DOE)

As of May 1 2025, DOE requires all covered individuals to:

Complete Research Security Training within 12 months prior to proposal submission.
Have an ORCID iD and include it in Current & Pending support disclosures

DOE Covered Individual Definition

An individual who (a) contributes in a substantive, meaningful way to the development or execution of the scope of work of a project proposed for funding by DOE, and (b) is designated as a covered individual by DOE.

DOE designates as covered individuals any principal investigator (PI); project director (PD); co-principal investigator (Co-PI); co-project director (Co-PD); project manager; and any individual regardless of title that is functionally performing as a PI, PD, Co-PI, Co-PD, or project manager.

DOE departmental elements will often expand this list of designated roles, as specified in the applicable Notice of Funding Opportunity (NOFO) and/or terms and conditions of the Federal financial assistance award. 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" if they meet the definition in (a) above.

See:

DOE Malign Foreign Talent Recruitment Program Certification

The in Current and Pending Support documentation and does not allow participation in Malign Foreign Talent Recruitment Programs.

within their Current and Pending Support.

National Science Foundation (NSF)

Effective October 10, 2025, NSF requires all covered individuals to:

Complete Research Security Training within 12 months prior to proposal submission.

NSF Covered individual Definition

Principal investigators (PIs) and other senior/key person seeking or receiving Federal research and development funding (i.e., extramural funding) and researchers at Federal agency laboratories and facilities (i.e., intramural researchers, whether or not federally employed), including Government-owned, contractor-operated laboratories and facilities.

See

NSF Research Security Training Requirements

Effective October 10, 2025, . This training must be completed by all covered individuals (key personnel) prior to proposal submission to NSF.

NSF Malign Foreign Talent Recruitment Program Certification

Effective May 20, 2024, covered individuals must individually certify that they are not a party to a malign foreign talent recruitment program. The SciENcv Biographical Sketch and Current and Pending (Other) Support documents require each individual to certify that the information provided is accurate, current, and complete, and that they are not a party to a malign foreign talent recruitment program. Effective June 7, 2025, all PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov that they are not party to a MFTRP.

National Institutes of Health (NIH)

Effective October 1, 2025, NIH requires all senior/key personnel:

•��Complete disclosure training at Just-In-Time

Effective May 25, 2026, NIH requires all senior/key personnel:

•��Complete research security training prior to proposal submission

NIH Covered Individual Definition

A “covered individual" is defined as all senior key personnel (i.e., individuals who contribute to the scientific development or execution of a project in a substantive, measurable way).

NIH Research Trainings

Disclosure Training: Effective October 1, 2025, NIH requires senior/key personnel complete disclosure training at Just-In-Time.

You may choose either the CITI Research Security Training 1-hour or 4-hour course which will satisfy both the NIH Research Security Training requirement and the Disclosure training requirement.

Research Security Training: Effective May 25, 2026, NIH requires senior/key personnel complete research security training prior to proposal submission.

This training must be completed by all covered individuals (senior/key personnel) prior to proposal submission to NIH.

In accordance with the Chips and Science Act, each covered individual must certify that they have completed the training within 12 months of the date of application submission. This certification will be collected at the time of application submission, through the Biographical Sketch in SciENcv.

NIH Malign Foreign Talent Recruitment Programs

Principal Investigators and Key Personnel on NIH awards are currently prohibited from MFTRP participation. For more information, please review the

Training Options for Covered Individuals

�� has added the to our CITI Program training portfolio of courses. Researchers have training options available through the online CITI Program that will satisfy the research security training requirement.

�� will accept either the course or the condensed to satisfy the initial requirement.

*NOTE: The CITI Research Security Training: A Basic Course (20 minute course) does not satisfy the federal research security training requirement and should only be selected as an add-on course to the RCR training.

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