New Research Security Training Requirements for Federal Grants


Department of Energy (DOE) requirements

Starting May 1, 2025, all principal investigators and key/senior personnel submitting new proposals to the Department of Energy (DOE) are required to complete research security training within 12 months before proposals can be submitted.

Research Security & Integrity (RSI), in partnership with the Office of Contracts and Grants (OCG), has established processes and procedures to comply with the new 听research security training requirement outlined by DOE. Senior/Key Personnel (or Covered Personnel as determined by DOE) must within a year prior to the submission of a proposal to DOE.

Note: This requirement does not impact existing DOE grant awards.

View the official guidance from DOE outlining this requirement:

Questions about the new DOE requirements

Anyone DOE deems as 鈥淐overed Personnel鈥 on the proposal is required to take Research Security training within a year prior to proposal submission. In most cases, Covered Personnel will be Senior/Key Personnel who provide biographical sketches at the time of proposal. However, DOE may further specify who is considered 鈥淐overed Personnel鈥 within the funding opportunity announcement.

  • The content is based on NSF鈥檚 four Research Security Modules. Lesson titles include Course Introduction, What Is Research Security, Disclosure, Manage & Mitigate Risk, and International Collaboration.
  • The content helps users understand their research security responsibilities as defined by sponsoring agencies and provides guidance around who to contact at the university for support.
  • Users must receive at least an 80% on a 5-question quiz at the conclusion of the course to complete their training requirement.
  • The Research Security training course is a self-paced online course , 91传媒鈥檚 Learning Management System.
  • When CU employees complete the course and pass the quiz, their completion data will be recorded in SkillSoft Percipio. Reports will be pulled from SkillSoft Percipio to confirm individual completion.
  • 91传媒 has adapted content from NSF鈥檚 four Research Security training modules, which take 4 hours to complete in total, into a more concise, CU-specific training that should take approximately 75 minutes or less to complete.
  • The course does not have to be completed in one sitting. The user can save their progress and return to the course at any time.
  • Individuals must have a training completion date within twelve months prior to the submission of the proposal.
  • For DOE proposals, OCG Proposal Analysts will consult with the 91传媒 PI to determine which individuals on the project are required to complete Research Security training.
  • Subrecipients:听The 91传媒 PI will also consult with their subrecipients to determine who is required to complete Research Security training. Subs will complete their Research Security training requirement in compliance with their home institution鈥檚 processes.
  • Prior to the submission of the proposal, the OCG Proposal Analyst will review data from a SkillSoft Percipio report to confirm training completions for the 91传媒 employees identified by the PI.
  • Subrecipients: Subrecipient training completion is verified by the subrecipient insitution through the Subrecipient Commitment Form or the Subrecipient Statement of Collaborative Intent.
  • When the proposal is submitted, the OCG Proposal Analyst (as CU鈥檚 Authorized Organizational Representative) is certifying to 91传媒鈥檚 compliance with the sponsor鈥檚 Research Security training requirement.
  • Below is the certification language for DOE:
    • The research security training requirement described here is optional until May 1, 2025, and mandatory thereafter. Recipients must maintain a research security training program for covered individuals on the project, consistent with Section 10634 of the CHIPS and Science Act of 2022. Any new covered individuals at the recipient and subrecipient levels added to the project must certify that they have completed the training within thirty (30) calendar days of the individual joining the project (see Current and Pending Support term for certification instructions).
      • In addition, recipients must maintain sufficient records (records must be retained for the time period noted in 2 CFR 200.334 and made available to DOE upon request) of their compliance with this requirement for covered individuals at the recipient organization and they must extend this requirement to any and all subrecipients. To fulfill this requirement, recipients may utilize the four one-hour training modules developed by the National Science Foundation at听 or develop and implement their own research security training program aligned with the requirements in Section 10634(B) of the CHIPS and Science Act of 2022.
      • Acceptance of the award or use of the first dollar of award funds constitutes the recipient鈥檚 acceptance of this requirement and all other applicable award requirements.
      • Covered individuals previously identified by the recipient who have already certified and completed the research security training do not need to complete it again, even if they are submitting an updated Current and Pending Support Form during the life of the award.

Upcoming National Science Foundation (NSF) requirements

In addition to the new DOE research security training requirements, we have also been notified that NSF requirements will be enhanced starting in Fall 2025. We will provide details and resources related to new NSF requirements to campus as soon as details are available.听

View current official guidance from NSF:

Questions?

Please contact Justin Mack, Director, Research Security & Export Controls:听justin.mack@colorado.edu.

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