Research Security Training
The NSPM-33 and CHIPS and Science Act of 2022 mandate that principal investigators (PIs) and essential personnel complete annual research security training based on a schedule established by federal funding agencies. Beginning May 1, 2025, the Department of Energy (DoE) and the National Nuclear Security Administration (NNSA) will be the first to enforce this training requirement for new proposal submissions. Other federal funding agencies, including the NSF and NIH, are anticipated to reveal their implementation dates in 2025 or early 2026.
Requirement: To meet the research security training requirement, Tulane mandates that all "covered individuals" (defined below) involved in DoE awards undergo research security training by May 1, 2025. After this date, the DoE will require proof that all covered individuals mentioned in the proposal have completed the training within the year prior to the proposal submission. The Sponsored Projects Administration (SPA) will not submit any DoE proposals on or after May 1, 2025, unless all covered individuals have completed their training. Additionally, any newly covered individuals added to the project must certify their training completion within 30 calendar days of joining.
Be aware that certain RFPs may mandate all project participants to confirm they have received research security training. Check your RFP for these requirements and make sure every project participant completes the training.
Researchers with federal grants are urged to undergo this research security training in preparation for the forthcoming implementation dates set to be revealed by different federal funding agencies. This training is accessible to all Tulane employees and will equip you for this obligation once your specific funding agencies adopt it.
Applicability: The law introduces a new term of "covered individuals" subject to this research security training requirement.
A covered individual is an individual who:
- Contributes in a substantive, meaningful way to the development or execution of the scope of work of a project proposed for funding by a federal agency; and
- Is designated as a principal investigator (PI), project director (PD), co-principal investigator (Co-PI), co-investigator (Co-I), co-project director (Co-PD), project manager, key personnel, and any individual regardless of title (inclusive of consultants, graduate students, or postdoctoral associates) that is functionally performing in one of these named roles.
Upon submitting a proposal, covered individuals will include PIs, key personnel, and anyone designated by the PI who plays a significant role in the design, implementation, or reporting of the research. These individuals must complete research security training prior to submitting proposals for the DoE, starting from May 1, 2025.
Training: The goal of research security training is to provide you with the necessary knowledge and tools to understand the behaviors that have contributed to the improper or illegal transfer of research and development (R&D) supported by the U.S. government, as highlighted by incidents reported by federal research agencies. Additionally, this training will emphasize the essential role of U.S. researchers in global scientific advancements and the importance of drawing international talent to U.S. research institutions.
Tulane is leveraging the Collaborative Institutional Training Initiative (CITI) Program’s module on "Research Security Training (Combined)" to meet this training requirement. This CITI module is tailored for researchers and offers a streamlined version of the NSF’s four-hour Research Security Training modules. Please set aside 1.5 hours to complete the CITI training. You have the option to finish the training in stages and can save your progress along the way.
To complete the training, follow these steps:
- Register for the training through the Collaborative Institutional Training Initiative (CITI) Program.
- To create an account in CITI, click on the Register button in the upper right.
Returning users may login in the upper right corner.
- Under Institutional Courses, click View Courses next to Tulane University.
- At the bottom of the page, under Learner Tools for Tulane University, click on Add a Course.
- Page down to find Research Security and choose 'Research Security Training (Combined Course)'.
- Training is estimated to take 1.5 hours but is good for one year. It is sugggested you save your training certificate in the event it is needed over the course of the year.
- Your completion report should be shared with SPA and will also be accessible through the CITI program.
If you have difficulty locating or logging into the training, please email exportcontrols@tulane.edu.
For more information on Research Security and Export Controls, please visit the VPR Export Controls and Research Security pages at https://research.tulane.edu/compliance/foreign_influence and https://research.tulane.edu/compliance/export or reach out at exportcontrols@tulane.edu.
Thank you for addressing this significant new requirement. Your collaboration is vital for achieving these research security standards and maintaining Tulane's highest levels of compliance.
