Definitions
- RAF – Research Administration and Finance
- RSECO – Research Security and Export Control Office
- Senior/Key Personnel –
- NIH: “The Project Director (PD) / Principal Investigator (PI) and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically, these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered senior/key personnel if their involvement meets this definition. Consultants and those with a postdoctoral role also may be considered senior/key personnel if they meet this definition.”
- NSF: “Senior/key personnel include the individuals designated by the proposer/recipient organization and approved by NSF, who contribute 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.”
- 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 or proposed for funding; and (b) is designated as a covered individual. At a minimum, covered individuals are designated by 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. Status as a consultant, graduate (master’s or PhD) student, or postdoctoral associate does not automatically disqualify a person from being designated as a “covered individual” if they meet the definition in (a) above.[1]
Regulations
- Certification Regarding Research Security Training for Federal Research Award Personnel: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234), the Authorized Organizational Representative (AOR) must certify that all individuals identified as senior/key personnel have completed the requisite research security training that meets the requirements specified in Item 2 of Important Notice No. 149 within 12 months prior to proposal submission.
NIH:
- “This Guide Notice announces a new policy requirement that requires NIH recipients to provide training to all faculty and researchers identified as Senior/Key Personnel on the requirement to disclose all research activities and affiliations (active and pending) in Other Support (see Other Support form).
Effective October 1, 2025, recipients must implement trainings, in addition to maintaining a written and enforced policy, on requirements for the disclosure of other support to ensure Senior/Key Personnel fully understand their responsibility to disclose all resources made available to the researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.”
DOE:
- “The applicant certifies to the best of its knowledge and belief that each covered individual who is employed by the applicant and listed on the application has completed a research security training program consistent with Section 10634 of the CHIPS and Science Act of 2022.”
As of October 1, 2025, RPI will require completion of the CITI research security training module by all Covered Individuals (in most cases, Senior/Key Persons) at the time of proposal submission to any federal funding agency. Completion of this training requirement will ensure RPI’s compliance with federal research funding agency requirements. DOE currently requires completion prior to submitting research grant proposals; As of October 2025, NSF will require this training prior to submission and NIH will require training on Other Support and Biographical Sketch Disclosure, which is fulfilled by this same CITI module. We expect other agencies to follow suit.
Training Required: The required training is a one (1) hour CITI training course, described in more detail below.
Persons Who Must Take the Training: Covered individuals and senior key personnel
Timing: The Required Research Security Training Module must be completed by any Covered Individual named in a federal research proposal on or after October 1, 2025. The proposal will not be submitted after that date if all Covered Individuals named in the proposal have 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 will also highlight the critical role of U.S. researchers in global scientific research and the importance of international talent in research.
How to Complete the Requirement: To complete the training, follow these steps:
- Reference the Office for Research Required Training Website to review RPI required trainings and login 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.
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. After October 1st, 2025, you will not be able to submit a federal proposal, either directly or as a passthrough with a prime recipient, without proof of training completion.
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 in getting your proposals funded!