April 2025
Beginning May 1, 2025, the U.S. Department of Energy (DOE) will require all “covered individuals” listed in grant applications to complete annual research security training. We expect all other federal funding agencies to follow suit in mandating this training including the National Science Foundation (NSF) later this year when the agency issues its 2025 Proposal and Award Policies and Procedures Guide (PAPPG).
The U.S. 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 U.S. research and development (R&D) enterprise. Therefore, the federal government continues to take steps to protect the investment in R&D. As a result of that effort, federal agencies have been directed to require investigators to take an annual training on research security before submitting applications for funding.
The DOE is the first agency to implement the requirement, effective for applications submitted on and after May 1, 2025.
A “covered individual” is defined as anyone who contributes in a substantive, meaningful way to the scientific development or execution of an R&D project proposed to be carried out with an award from a federal research agency — and is designated as a covered individual by the federal research agency.
At a minimum, any individual designated as key personnel in an application will be considered a covered individual.
Research compliance training has been developed that complies with federal guidance and is available on the Collaborative Institutional Training Initiative (CITI Program) website. The training will take approximately one hour to complete.
The CITI Program’s Research Security combined training modules are accessible to University of Missouri – Kansas City personnel using single-sign-on (SSO) authentication from any computer with internet connectivity. Instructions:
Starting May 1, 2025, DOE will require covered individuals to have completed research security training within a year before the date a grant application is submitted. Other agencies will be providing implementation dates independently. However, you should anticipate that all agencies will require training for R&D applications soon.
We encourage all researchers to complete the training well in advance of application due dates.
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 at research institutions.
The National Science and Technology Council of the Office of Science and Technology Policy (OSTP) released guidance for implementing NSPM33 on Jan. 4, 2022. The document provides agencies with guidance on implementing research training programs. The Council on Government Relations has provided an overview of the July 2024 OSTP “Guidelines for Research Security Programs at Covered Institutions.”
The Chips and Science Act is legislation that was signed into law in August 2022. The legislation includes authorization for funding in the area of semiconductors. In addition, the act also has many research security provisions, including training requirements. The Association of American Universities has provided a summary of those research security provisions.
The Department of Energy training requirements are articulated in Financial Assistance Letter No. FAL 2025-02.
The National Science Foundation training requirements are articulated on their Research Security Training website, which includes helpful answers to frequently asked questions.
Jordan Strayer, Research Security Officer
University of Missouri-Kansas City
Office of Research Security
j.strayer@umkc.edu