Section 10634 of the CHIPS and Science Act of 2022 requires federal grant making agencies to establish research security training requirements applicable to both Covered Personnel (Key Personnel) listed on an application for a research and development award and their sponsoring institutions. These requirements musts include certification procedures to ensure that all Covered Personnel have taken appropriate research security training within one year of the application.
The definition of a "Covered Personnel" includes those who "contribute in a substantive, meaningful way to the scientific development or execution of a research and development project" under an award from a federal agency. This includes PIs, Co-Is and anyone designated as "senior personnel."
The following federal agencies have released specific guidance addressing their implementation of this research security training requirement. Please note that the University of Pittsburgh’s approved Research Security Training fulfills all of the requirements for the agencies in the tabs below.
A link to the University of Pittsburgh’s approved Research Security Training found on CITI is also listed below.
- Department of Energy
-
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.
- National Science Foundation
-
Requirement for Research Security Training is effective October 10, 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. - National Institutes of Health
-
Requirement for Other Support/Research Security Training is effective October 1, 2025
Per the NIH's July 17, 2025 NOT-OD-25-133:NIH recipients are required to provide training to all faculty and researchers identified as Senior/Key Personnel on the requirement to disclose all research activities and affiliations (active and pending) in Other Support (see Other Support form). The new requirement to train researchers to comply with other support disclosure requirements adds to the current policy (see NIH Grants Policy Statement [GPS], Section 2.5.1 "Just-in-Time Procedures") in order to provide a comprehensive plan in the area of disclosure requirements for recipients.
Effective October 1, 2025, recipients must implement trainings, in addition to maintaining a written and enforced policy, on requirements for the disclosure of other support to ensure Senior/Key Personnel fully understand their responsibility to disclose all resources made available to the researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.
- US Department of Agriculture
-
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. - Federal Research Security Training on CITI
-
University Announcement Circulated in April 2025
- University of Pittsburgh Research Security Trainings By Topic
-
ORSTC is creating a series of topic-specific trainings for the Pitt Research community. More will be added soon!
Foreign Talent Recruitment Programs
Foreign Talent Recruit Programs: Policies and Requirements
Risk Mitigation for Researchers
Risk Mitigation Awareness for Researchers
