Mandatory New NSF Research Security Training and Documentation Requirements

Mandatory Research Security Training

All senior/key personnel listed on NSF proposals must complete a compliant research security training, such as rED 367 or the CITI module for research security, PRIOR to submission.  Certification of completion is required at the time of proposal submission. 

This certification took effect on December 2nd and is provided separately for each individual designated as senior/key personnel on the proposal.

• • 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 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.

Prior to making funding recommendations, the NSF program officer will request updated versions of the Current and Pending (Other) Support be submitted via Research.gov.

This training must be renewed annually.  Re-certification is required annually thereafter for the duration of the award. Updated Current and Pending (Other) Support must be disclosed to NSF when annual and final progress reports are submitted.

Additionally, NSF requires all faculty, staff, students, and postdoctoral researchers supported by NSF-sponsored projects to complete rED 367 or the CITI module for research security. This requirement is in addition to the required Responsible Conduct of Ethical Research (RCER) training. 

 

Expanded Documentation Requirements

The University is required to provide supporting documentation including proof of research security training completion, copies of foreign appointments, contracts, employment agreements, and participation in foreign talent programs upon request by NSF. 

Senior/key personnel must maintain these supporting documents and make copies available upon request. 

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Reminder of Existing Non-Participation in Malign Foreign Talent Recruitment Programs (MFTRPs) 

Individuals who are party to a Malign Foreign Talent Recruitment Program are not eligible to serve as a senior/key person on an NSF proposal. 

This certification took effect on May 20, 2025 and is provided separately for each individual designated as senior/key personnel on the proposal.

• • 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.
    • See also NSF disclosure requirements

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NSF Definition of Malign Foreign Talent Recruitment Programs 

Any program, position, or activity that is sponsored by one of the following:

• • A foreign country of concern (defined as the People's Republic of China including Hong Kong and Macau, the Democratic People's Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country determined to be a country of concern by the Secretary of State); or
  • An entity based in a foreign country of concern; or
  • An institution or program on certain prohibited lists (contact OSP for restricted party screening).

AND

Involves one or more of the following:

• • Unauthorized transfer of intellectual property, materials, data or other nonpublic information;
  • Recruitment of trainees or researchers to enroll in such program, position or activity;
  • Establishing a laboratory or entity in a foreign country in violation of terms and conditions of a federal research award;
  • Accepting a faculty position, or undertaking any other employment or appointment in violation of the standard terms and conditions of a federal research award;
  • Being unable to terminate the activity except in extraordinary circumstances;
  • Being limited in capacity to carry out a federal research award;
  • Requirement to engage in work that overlaps or duplicates a federal research award;
  • Requirement to obtain research funding from the foreign government’s entities;
  • Requirement to omit acknowledgment of the U.S. home institution and/or the federal funding agency;
  • Requirement to not disclose participation in the program, position, or activity; OR 
  • Having a conflict of interest or commitment contrary to a federal research award.

Questions regarding Research Security or Foreign Influence should be sent to the Research Security Office. Questions re: NSF certifications should be sent to your Sponsored Projects Officer.