What are Federal Sponsor Research Security Requirements?
This page will continue to be updated as we receive more information.
Some federal sponsors have upcoming Research Security requirements which must be met by all covered individuals. These requirements can include Research Security Training, ORCID iDs, and certifications or disclosures that awardees are not participating in Malign Foreign Talent Recruitment Programs.
While the UW prohibits participation on MFTRPs, some sponsors require additional certifications or disclosures. Definitions and requirements may vary by sponsor.
Guidance, definitions, and requirements may vary by sponsor. Basic information from some of our federal sponsors is listed here for reference.
If a sponsor is not listed, it does not necessarily mean they do not have a requirement, please refer to sponsor guidance.
Definitions & Requirements by Sponsor
Dept. of Energy (DOE)
As of May 1 2025, DOE requires all covered individuals to:
- Complete all four CITI research security training modules prior to proposal submission
- Have an ORCID iD and include it in
- Current & pending support disclosures
- Publications resulting from awards
DOE Covered Individual Definition
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
DOE Malign Foreign Talent Recruitment Program Certification
The DOE requires full disclosure of foreign involvement in Current and Pending Support documentation and does not allow participation in Malign Foreign Talent Recruitment Programs.
All covered individuals must certify that they are not currently participating in a malign foreign talent recruitment program (MFTRP) within their Current and Pending Support.
NASA
NASA Covered Individual Definition
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
NASA Research Security Training Requirement
Coming Soon!
NASA Malign Foreign Talent Recruitment Program Certification
Upon completing a biographical sketch and current and pending support form, senior/key
personnel will be required to sign a certification statement reading “I also certify that, at the time of submission, I am not a party to a malign foreign talent recruitment program.” This certification will be required annually and kept on file.
National Institutes of Health (NIH)
NIH Covered Individual Definition
A “covered individual” is defined as all senior key personnel (i.e., individuals who contribute to the scientific development or execution of a project in a substantive, measurable way). This covered individual definition is applicable to SBIR and STTR applicants for purposes of the SBIR and STTR Foreign Disclosure Form.
NIH Research Security Training
Coming Soon!
NIH Malign Foreign Talent Recruitment Programs
Principal Investigators and Key Personnel on NIH awards are currently prohibited from MFTRP participation.
National Science Foundation (NSF)
NSF Covered individual Definition
Principal investigators (PIs) and other senior/key person seeking or receiving Federal research and development funding (i.e., extramural funding) and researchers at Federal agency laboratories and facilities (i.e., intramural researchers, whether or not federally employed), including Government-owned, contractor-operated laboratories and facilities.
See NSF Proposal & Award Policies & Procedures Guide (PAPPG)
NSF Research Security Training Requirements
Coming Soon!
NSF Malign Foreign Talent Recruitment Program Certification
Effective May 20, 2024, covered individuals must individually certify that they are not a party to a malign foreign talent recruitment program. The SciENcv Biographical Sketch and Current and Pending (Other) Support documents require each individual to certify that the information provided is accurate, current, and complete, and that they are not a party to a malign foreign talent recruitment program.