Background

National Security Presidential Memo 33 (NSPM33) was issued in January 2021. The memo directs agencies to focus on improving research security in several areas, including research security programs for research institutions. The National Science and Technology Council of the Office of Science and Technology Policy (OSTP) released guidance for Implementing NSPM33 on January 4, 2022. The document provides agencies with guidance on implementing research training programs. The Chips and Science Act is legislation signed into law in August 2022. The legislation includes authorization for funding in semiconductors. In addition, the act also has many research security provisions, including training requirements.

Overview

Beginning in May 2025, the Department of Energy (DOE) will require all “Covered Individuals” listed in a proposal application to complete research security training. All federal funding agencies will eventually implement this same research security training requirement. Hence, we recommend that any Principal Investigator (PI) pursuing federal funding should take this training as soon as possible.

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 R&D. As a result of that effort, federal agencies have been directed to require Covered Individuals to take annual training on research security before 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 funding agency and is designated as a Covered Individual by the federal funding agency.
 

At Proposal

Procedure

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

1. Complete the “Research Security Training Combined” course in CITI before submitting a proposal.
   1. If the Covered Individual cannot access the CITI training module, they should contact export.control@umkc.edu to get access to an alternative training module located in eCompliance before submitting a proposal.

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

1. If the non-UMKC Covered Individual is part of a subcontract, their institution should confirm that the Covered Individuals from their institution completed Research Security Training within the last year.
2. If the non-UMKC Covered Individual will directly support UMKC’s work on a federally funded contract, they should contact export.control@UMKC.edu to get access to an alternative training module located in eCompliance.

UMKC’s Research Security Officer (RSO) will:

1. Work with the PI to complete the Covered Individual Form.
2. Verify via eCompliance that all UMKC Covered Individuals completed Research Security Training.
3. If there are non-UMKC Covered Individuals on the proposal, confirm the Subrecipient verified that their Covered Individuals 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 export.control@umkc.edu.

At Award

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

During the Project

All Covered Individuals must complete this training annually. If a project lasts more than a year, Covered Individuals must retake the training each year until the project concludes.