Research Security Training
Please review this collection of frequently asked research security training requirement questions. If you have further questions reach out to researchsecurity@uw.edu.
For more guidance on specific federal requirements review:
What are Federal Sponsor Research Security Requirements?
When does the training need to be taken?
Q1: Will this apply only to new proposal submissions or to all existing awards as well?
A1: Currently, this requirement applies to new proposal submissions only. If the agency guidance changes on this point, we will update the campus community.
Q2: Must the training be completed before proposal submission? Can we meet the requirements at the Just-in-Time stage instead?
A2: No. The Institutional Certification is certifying all covered individuals have completed the training at the time of submission. It must be complete for the proposal to be considered Ready to Submit. If the certification wording varies in
the NOFO, that will be taken into account. We recommend that the training be taken as soon as convenient so it is not down to the last few days before the proposal due date.
Who do these requirements apply to?
For more specific guidance on specific federal requirements review:
What are Federal Sponsor Research Security Requirements?
Some federal sponsors (e.g. DOE) have upcoming Research Security Training requirements which must be met by all covered individuals participating on a project before a proposal can be submitted as of May 2025.
Q1: Who is considered a “covered individual”?
A1: The definition of covered individual varies depending on the federal agency. Generally, however, it is:
An individual who (A) 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 (B) is designated as a covered individual by the Federal research agency concerned.” See Office of Science and Technology Policy (OSTP) Memo
Some specific definitions:
CHIPS and Science Act
(1) COVERED INDIVIDUAL.—The term ‘‘covered individual’’ means an individual who— (A) 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 research agency; and (B) is designated as a covered individual by the Federal research agency concerned. See: Section 10638(1) of the CHIPS and Science Act
Department of Defense (DoD)
Covered Individual: An individual at an extramural research institution who contributes significantly to the design and/or execution of a fundamental research project {ADDLINK to definition} that is, or if selected for award would be, funded, in whole or in part, by the DoD, and who is considered essential to the successful performance of the fundamental research project. Covered individuals include those listed as key personnel in fundamental research project proposals, such as the principal investigator or co-principal investigators. See: Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education
Department of Energy (DOE)
Covered Individual means 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 by DOE, and (b) is designated as a covered individual by DOE.
DOE designates as covered individuals 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.
DOE departmental elements will often expand this list of designated roles, as specified in the applicable Notice of Funding Opportunity (NOFO) and/or terms and conditions of the Federal financial assistance award. 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. See: FAL Research Security Training Requirements for all R&D Financial Assistance Awards
NASA
NASA will designate as a covered individual any PIs (regardless of level of effort), any Co-PIs (regardless of level of effort), and only Co-Is proposing to spend ten percent or more of their time in any given year on a NASA-funded award. NASA funding organizations may designate additional personnel categories as covered individuals on a project-by-project basis, and these designations will be explicitly stated in all NOFOs. See: NASA Grant and Cooperative Agreement Manual
Office of Science Technology Policy (OSTP)
Covered individual – The term “covered individual” has the meaning given such term in Section 10638(1) of the CHIPS and Science Act (42 U.S.C. 19237(1)). See: OSTP 2024 Foreign Talent Recruitment Guidelines
Q2:Will research security training be required for grad students or postdocs holding NSF or other federally funded fellowships? Same question on training grants: are both mentors and the trainees required to take this?
A2: Yes, if they meet the agency’s definition of a covered individual. We expect mentors, trainees, and those holding the fellowships will fall under the definition. However, you will need to review the NOFO to confirm this before routing the proposal.
Q3: Are students and postdocs required to complete the training?
A3: Any student or postdoc listed by name or filling a TBN position on the PI, Personnel and Organizations page of the application should complete training, if they also meet the definition of Covered Individual.
How can I check to see if my researchers have taken the appropriate training?
Q1: What report can I use to see my researchers’ training status?
A1: Use your UW NetID to access the Research Security Training Lookup reporting tool and download a copy. For issues accessing the report, contact orishelp@uw.edu.
Q2: How do I download and refresh the report’s data? Can I create a custom report for my department?
A2: Review the How do I access, download, and refresh key reports? FAQ.
Are there other options for training?
Q: Can the UW select a different research security training course?
A: These are the federally-approved modules. We opted for these as they are
accepted broadly by the agencies and also fulfill other research security related training
requirements (for example, travel security training). We understand that NSF is reviewing the content, tone and format of the existing training modules and may issue revisions in the future. UW is investigating other training curricula for possible consideration.
What about subawards?
Q: What about named subaward key personnel and individuals at other institutions, foreign or domestic? Are we (PI/unit) responsible for confirming the subrecipients named have completed the training and if so, do we need to have them include that confirmation in their letter of intent?
A: All covered individuals named in a subrecipient’s proposal that is integrated into UW’s application must take the training. That subrecipient entity’s signed Letter of Intent (LOI), signed by their institutional official, is a reflection they will abide by sponsor requirements. We rely on the letter of intent from the subrecipient as confirmation they are following requirements. Note, the training modules are available on NSF’s website, if the subawardee doesn’t have their own training resources.
Technical Issues with CITI Training?
Q: Where can I get help in resolving issues with the CITI training?
A: For technical issues, contact CITI directly at 888.529.5929 (9:00 a.m. to 7:00 p.m. / U.S. Eastern Time / Monday – Friday) or support@citiprogram.org. For policy questions, contact researchsecurity@uw.edu.