What's New Since This Page Was First Posted
| When RPI adopted this requirement in October 2025, only DOE, NSF, and NIH required research security training. Since then USDA and NASA have made the training mandatory, and Department of War modules began adding the requirement to funding opportunities and award terms and conditions. Research security training is now required by nearly every major federal research sponsor. RPI's requirement has not changed: if you are named on a federal proposal, complete the training before the proposal is submitted and renew it every 12 months. |
Quick Reference
| Who | What | When | Why It Matters |
|---|---|---|---|
| Covered Individuals and Senior/Key Personnel (in most cases, the PI, Co-PIs and other senior personnel) named on any federal proposal, including federal pass-through proposals. | CITI Research Security Training (Combined), a one-hour course. | Before proposal submission, and within the 12 months before the submission date. Renew annually. | Federal sponsors largely require this training for all covered individuals on sponsored projects. Per RPI policy, RPI will not submit a federal proposal until every Covered Individual named on it has a current completion record. |
Definitions
| Term | Meaning |
|---|---|
| RAF | Research Administration and Finance |
| RSECO | Research Security and Export Control Office |
| Senior/Key Personnel | Practical Rule: In most cases, research security training is required for the PI, Co-PIs, and all Senior/Key Personnel or Covered Individuals named in a federal proposal. Because sponsor definitions vary, investigators should review the solicitation and award terms to determine whether additional personnel, including project managers, students, postdoctoral associates, consultants, or personnel added after award, must also complete the training. |
| Covered Individual | An individual who (a) contributes in a substantive, meaningful way to the development or execution of the scope of work of a project proposed for funding, and (b) is designated as a covered individual. At a minimum this includes any PI, PD, Co-PI, Co-PD, project manager, and anyone functionally performing in those roles. Status as a consultant, graduate student or postdoctoral associate does not automatically exclude someone. Note: NASA limits Co-Investigators to those at 10% effort or more; USDA's definition is broader and can include students who meet it. |
Federal Sponsor Requirements
All of the following implement Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234). Each requires training prior to proposal submission, and each accepts the CITI course RPI uses. You will certify your training on the biosketch or current and pending support form for the proposal; RAF certifies on RPI's behalf.
| Sponsor | Agency Notice | Who Must Complete It |
|---|---|---|
| DOE | FAL 2025-02 | While requirements vary slightly by sponsor, most require training for the PI, Co-PIs, and all Senior/Key Personnel or Covered Individuals named on the proposal: anyone who contributes substantively to designing or carrying out the research, whatever their title. Some sponsors go further, such as USDA including students and postdocs, or require training for people added after award, so always check the solicitation. |
| NSF | Important Notice No. 149 | |
| NIH | NOT-OD-25-133 NOT-OD-26-017 | |
| USDA | USDA Terms (June 2026) | |
| NASA | GIC 26-02 | |
| DoD / DoW | Check the Solicitation | |
| All Other Federal Sponsors, Including Pass-Through Entities | RPI Policy |
RPI Requirement
As of October 1, 2025, RPI requires completion of the CITI research security training module by all Covered Individuals (in most cases, Senior/Key Personnel) at the time of proposal submission to any federal funding agency. Completion of this training ensures RPI's compliance with federal research funding agency requirements, and the same CITI module also satisfies NIH's training on Other Support and Biographical Sketch disclosure.
Training Required: The required training is a one (1) hour CITI training course.
Persons Who Must Take the Training: Covered Individuals and Senior/Key Personnel on any federal or federal pass-through proposal.
Timing: The training must be completed before submission by every Covered Individual named in a federal research proposal, and completion must be within the 12 months before the submission date. One completion covers all of your federal proposals for 12 months; after that, take it again. The proposal will not be submitted if any Covered Individual named in it has not completed the training.
Training Content: The training module is designed to equip you with knowledge necessary to understand risks and avoid behaviors that can lead to improper or illegal transfer of information from government-supported research and development. It also highlights the critical role of U.S. researchers in global scientific research and the importance of international talent in research.
How to Complete the Requirement
- Reference the Office for Research Required Training Website and log in to the Collaborative Institutional Training Initiative (CITI) Program.
- Register for the Research Security (Combined) module.
- Complete the required training and ensure you receive a completion report.
- Renew every 12 months. Note your completion date so your training does not lapse before your next proposal.
A copy of your Completion Report will automatically be shared with Research Administration and Finance (RAF) and will be accessible to you and RAF at any time from the CITI Program. You will not be able to submit a federal proposal, either directly or as a pass-through with a prime recipient, without proof of current training completion.
Tips for PIs
- Check your whole team early. The proposal is at risk for being held by RAF if anyone named on it is missing a current completion record, not just the PI.
- Read the solicitation. Some sponsors, including NASA and DoD/DoW, may name additional people who must complete training.
- New team members after award. Some sponsors (for example, NASA and USDA) require people added to a funded project to complete training too.
- Not the same as RCR. Responsible Conduct of Research courses do not satisfy this requirement.
Thank you for your attention to this important matter. Your cooperation is essential in maintaining the highest standards of research security and compliance at RPI, as well as in getting your proposals funded.
Questions?
Contact the Research Security and Export Control Office, Office of the General Counsel, Troy Building, 110 Eighth Street, Troy, NY 12180, 518-276-3777.
See also the Supplemental Information to the Policy.