Research Compliance Update: Research Security Training and New DOE Conflict of Interest Requirements
Sent to all faculty on Monday, October 12, 2026
Below is key information on research compliance for research-active faculty.
Key Takeaways
- ✅ Most major federal sponsors now require research security training.
- ✅ Training must have been completed within the 12 months before proposal submission.
- ✅ Training must be renewed every year.
- ✅ DOE proposals may require additional internal review, so start routing them early.
Reminders on Research Security Training
RPI has updated its Research Security Training Requirements webpage. When RPI began requiring research security training in 2025, few sponsors required it. Since then, nearly all major federal research sponsors, including DOE, NSF, NIH, NASA, the Department of War, and USDA, have implemented research security training requirements under the CHIPS and Science Act.
📄 Updated guidance: Research Security Training Requirements | Office of the General Counsel
Action required
Please verify that you have completed CITI Research Security Training (Combined) within the last 12 months if you:
- Plan to submit a federal proposal in the coming months
- Are currently working on a federally funded project
- Expect to be named as PI, Co-PI, Senior/Key Personnel, or another Covered Individual on a federal proposal
Requirement
Timing
Initial completion
Before proposal submission (within the last 12 months)
Renewal
Every 12 months thereafter
RPI requirement
Federal proposals will not be submitted until all required personnel have current training.
New Department of Energy Conflict of Interest Requirements Now in Effect
DOE has implemented new proposal-stage conflict review requirements for certain Covered Individuals. Under these requirements, RPI must verify disclosures for Covered Individuals, review certain conflicts and outside activities, and disclose certain foreign-government-related conflicts at the proposal stage.
Because RPI must complete these additional disclosure and compliance reviews before submission, investigators planning DOE or DOE pass-through proposals should start the proposal process early and avoid last-minute submissions.
If you are preparing a DOE or DOE pass-through proposal
- Engage with RAF as early as possible by initiating a Cayuse proposal.
- List all Covered Individuals in Cayuse on the Investigators/Research Team page.
- Late submissions may not leave enough time to complete required reviews.
Who does DOE define as a Covered Individual?
DOE defines covered individuals as “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; and persons designated in the applicable Notice of Funding Opportunity (NOFO) or terms and conditions of the Federal financial assistance award,” and states that “submission of a current and pending support disclosure and/or biosketch/resume for a particular person serves as an acknowledgement that DOE designates that person as a covered individual.”
⚠️ Please do not wait until the last minute to begin internal routing of DOE proposals.
Questions?
Contact the Research Security & Export Control Office or RAF.
Thank you for your cooperation and continued attention to federal research compliance requirements.
Gregory Smith
Assistant Vice President, Research Administration & Security