OVERVIEW

In May 2025, the Department of Energy (DOE) began requiring research security training by all “Covered Individuals” listed in a proposal application. Since then, other select agencies are now required to implement training requirements for grant recipients, i.e. the National Science Foundation and institutions can expect similar guidance from other federal and non-federal agencies to be forthcoming soon. Therefore, Research Security Training (RST) will now be a required component of the proposal development process for all covered persons identified within a proposal application being submitted to ANY federal grant proposal (i.e.,  DOD, DOE, NIH, NSF, and others).

WHY IS TRAINING REQUIRED?

The United States Government provides significant support for basic and applied research to a variety of research institutions and programs. Some foreign governments have demonstrated an increased threat to the open and collaborative nature of the United States R&D Enterprise. Therefore, the federal government continues to take steps to protect its investment in Research & Development. As a result of that effort, federal agencies have been directed to require covered individuals to take annual training on research security PRIOR to submitting applications for funding.

WHO MUST TAKE THE TRAINING?

A “Covered Individual” is defined as anyone 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. At a minimum, this will apply to Project Directors/Principal Investigators, co-Principal Investigators and other key personnel as identified on the grant project.

Procedure

AT PROPOSAL STAGE

Covered Individuals (Senior/Key Personnel) that are UMKC personnel:

• Complete the “Research Security Training Combined“ course in CITI PRIOR to the submission of a proposal.
• This CITI training is accessible via SSO log-in by following instructions located in the announcement. 

Covered Individuals (Senior/Key Personnel) that are non-UMKC personnel:

• If the non-UMKC Covered Individual is part of a subcontract, their institution should confirm, via the Subrecipient Commitment Form, that the Covered Individuals from their institution have completed Research Security Training within the last year.
• If the Covered Individual will not be part of a subcontract, they should contact export.control@umkc.edu to get access to an alternative training module located in eCompliance.

Principal Investigator or Department – At proposal, the PI or Department Administrator will:

• Complete the Covered Individual Form.
• Verify that all UMKC Covered Individuals have completed Research Security Training through CITI.
• If there are non-UMKC Covered Individuals on the proposal, confirm the Subrecipient has attested that their Covered Individuals have completed the Research Security Training requirement.

If the subrecipient indicates that their Covered Individuals have not completed the Research Security Training requirement, they should contact ORI@umkc.edu to get access to an alternative training module located in eCompliance.

• Submit to Sponsored Projects the Covered Individual Form, eCompliance documentation showing all Covered Individuals and the date of their completed research training.

Sponsored Projects, Pre-Award – At proposal, the Grants & Contracts Administrator (GCA) will:

• Review the Covered Individual Form for completeness and accuracy compared to the proposal application forms.
• Review the documentation submitted by the PI/Dept verifying that all UMKC Covered Individuals listed on the Covered Individuals form have completed Research Security Training within the last 12 months.
• If a UMKC Covered Individual has not completed training, the GCA should immediately alert the PI and Dept to have that person complete the training.

AT AWARD STAGE

If there are additional Covered Individuals added to the project after proposal, the Principal Investigator (PI) needs to ensure that individual(s) complete Research Security Training. No additional steps are needed to process the award for this certification.

DURING PROJECT

All Covered Individuals must complete training annually via CITI.

WHO SHOULD I CONTACT FOR QUESTIONS?

Jordan Strayer, Research Security Officer
University of Missouri-Kansas City
Office of Research Security
j.strayer@umkc.edu