Research Security Training Requirement
Research Security Policy
The National Security Presidential Memorandum-33 (NSPM-33) expressed the significant need to
“strengthen protections of United States Government-supported R&D against foreign government
interference and exploitation” while “maintaining an open environment to foster research discoveries
and innovation that benefit our nation and the world.” In January 2022, the Office of Science and
Technology Policy (OSTP) committed to providing clear and effective guidance for how agencies (and
resulting partners and recipients) could effectuate this effort. The July 2024 OSTP Memorandum then
provided Guidelines for Research Security Programs at Covered Institutions, which included
requirements for an institutional research security program and training, cybersecurity awareness and
practices, international travel tracking and training, and export control training.
Research Security Training Requirements
Consistent with Section 10634 of the CHIPS and Science Act of 2022, recipients must now maintain a
research security training program for covered individuals. Research security training is currently
required by the Department of Energy (effective May 1, 2025), the USDA and National Science
Foundation (effective October 10, 2025), and the National Institutes of Health (effective January 25,
2026) for all senior/key personnel (“covered personnel”). It is anticipated that additional federal
agencies will implement similar requirements in the near future.
Each covered individual listed on an application for a research and development award must certify that
they have completed research security training within one year of such application. This certification is
included in each proposal, via individual Current & Pending Support documentation developed in
SciENcv (or the applicable agency forms). Any new covered individuals added to the project (both at
Clarkson and at subrecipient organizations, as applicable) must certify that they have completed the
training within thirty (30) calendar days of the individual joining the project. If senior/key personnel are
modified during the life of the award, PIs are responsible for ensuring that these individuals are current
on their training. Clarkson must also certify that each covered individual that is an employee of Clarkson
and listed on the application has completed such training. The completion of training is valid for one
year (for the “Research Security Training (Combined)” Course), and requires annual renewal as long as
the relevant projects are active.
You will need to complete the training described below and submit the certificate of completion
before we will be able to submit the application for funding to the agency. Please also note that this
requirement also extends to any senior personnel who may be involved in your project through a
subaward/subcontract to their organization from Clarkson University. If that is the case, they will also
need to complete the required training prior to the proposal submission.
Please note that these training modules are also available through the CITI Training Program that
Clarkson University utilizes for sponsored research-related training. You can access these training
modules through the following link: https://about.citiprogram.org/
The CITI training program allows you to complete the required training by taking either a 1-hour
condensed course or four separate modules for a more in-depth overview of the topics. Either option
satisfies the federal requirement for Research Security Training. You may complete either the 1-hour
condensed course or the 4 modules. (Please also note when looking at the courses in the CITI course
library that the “Combined” course differs from the “Refresher” course. The “Refresher” course does not
satisfy the federal requirements for the initial training.)
If you access the training modules through the CITI Training Program link, we should be able to track
your completion status through the CITI program. You also have the option to complete the similar
course(s) provided by NSF if you would prefer (https://www.nsf.gov/research-security/training). If
you complete the course through the NSF link you will need to download your certification of
completion and forward to us here at the Sponsored Research Office
(proposals@clarskon.edu or srs@clarkson.edu)
Once you have completed either the 1-hour condensed course or each of the four modules module,
please send us copies of your certificate(s) of completion so that we’ll have them on file in case they
are requested by the funding agency for verification.
If you have any questions or problems with the SRS-related CITI Training Programs please contact our
Research Compliance Professional, Courtney Travis at ctravis@clarkson.edu or x4338.