In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234) and National Security Presidential Memorandum-33 (NSPM-33) and the July 29, 2024 Office of Science and Technology Policy (OSTP) memorandum on Guidelines for Research Security Programs at Covered Institutions, each individual identified as a senior/key person must complete the requisite research security training within 12 months prior to proposal submission.

The U.S. National Science Foundation (NSF) issued Important Notice No. 149 outlining clear, actionable research security policies in alignment with the CHIPS and Science Act of 2022 (P.L. 117-167) and National Security Presidential Memorandum-33 (NSPM-33).

NSF requires research security training certifications from proposers and individuals identified as senior/key personnel by Union College. This training must address cybersecurity, international collaboration, foreign interference, and rules for proper use of funds, disclosure, conflict of commitment, and conflict of interest. Union College senior/key personnel are required to complete the condensed research security training module developed by the SECURE Center. This training is compliant with NSF’s research security training requirements.

Research Security Training Requirement for Federal Award Personnel: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234), each individual identified as a senior/key person must certify 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.

• Certification Regarding Research Security Training for Federal Research Award Personnel: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234), the Authorized Organizational Representative (AOR) must certify that all individuals identified as senior/key personnel 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.
  
• Certification Regarding Responsible and Ethical Conduct of Research (RECR) (Applies to Institutions of Higher Education Only): The AOR is required to complete a certification that the institution has a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate students, graduate students, postdoctoral scholars, faculty, and other senior/key personnel who will be supported by NSF to conduct research and that such training addresses mentor training and mentorship, training to raise awareness of potential research security threats, and Federal export control, disclosure, and reporting requirements.

These policies are effective October 10, 2025 and impact all submissions on or after this date.

The National Institutes for Health issued NOT-OD-25-133 and NOT-OD-25-154 outlining the new research security requirements for all Senior/Key Personnel, including the requirement to disclose all research activities and affiliations (active and pending) in Other Support (see Other Support guidance).

NIH fully supports the use of the NSF online research security training modules, including a condensed version of the four modules at the SECURE Center. The condensed version was designed to meet the government-wide research training security requirement in Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234). Union College senior/key personnel are required to complete the condensed research security training module developed by the SECURE Center. This training is compliant with NIH’s research training requirements.

Research Security Training Requirement for Federal Award Personnel: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234), each individual identified as a senior/key person must 1. certify that they have completed the requisite research security training that meets the requirements specified in NOT-OD-25-133 and NOT-OD-25-154within 12 months prior to proposal submission and 2. certify annually at the time of the Research Performance and Progress Report (RPPR) that they have completed the training within the past 12 months.

• Institutional Certification: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234), the Authorized Organizational Representative (AOR) must certify, via their signature on the face page of the application (i.e., SF424 R&R cover form), that all individuals identified as senior/key personnel have completed the requisite research security training that meets the research security training requirements within 12 months prior to application submission.
  
• Individual Certification (at the time of application): In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234) each individual identified as a senior/key person must certify that they have completed the requisite research security training that meets the research security training requirements within 12 months prior to application submission. NIH is exploring system solutions to collect this certification. As an interim solution, applicants must provide a certification, electronically signed by each individual identified as a senior/key person, as a flattened PDF in the ‘Other Attachment’ field of the R&R Other Project Information form of the application. The file for each senior/key person must be named ‘ResearchSecurities_[Name].pdf’ without quotations, where ‘[Name]’ is the name of the senior/key person.
  
• Annual Certification (at the time of the Research Performance Progress Report (RPPR)): Individuals serving as senior/key personnel must continue to certify annually that they have completed training within the past 12 months. NIH is exploring system solutions to collect individual certifications. As an interim solution, a certification, electronically signed by each senior/key personnel must be uploaded in RPPR Section G.1., Special Notice of Award and Funding Opportunity Announcement Reporting Requirements section as a flattened PDF file. The file for each senior/key person must be named ‘ResearchSecurities_[Name].pdf’ without quotations, where ‘[Name]’ is the name of the senior/key person.

These policies are effective October 1, 2025 and impact all NIH-funded proposals and awards.

Covered individuals are required to complete the required training within 12 months prior to the submission of a proposal to NSF or NIH. Thereafter, individuals serving as senior/key personnel on an NIH award must complete the training on an annual basis. The required condensed research security training module is accessible through the new Research Trainings course on Nexus. Trainees will be enrolled by the Office of College Grants and Sponsored Programs.

Once enrolled, trainees should select the link for the Research Security Training, as shown below:

To start the course, trainees should select the “Enter” button that appears on the screen and should then follow the prompts that appear to begin the course and navigate through the training. The training should take around an hour to complete. It does not need to be completed in one sitting. Trainees can pause the training at anytime and return to the training at a later time.

Upon completion of the training, trainees will be required to enter their name into a certificate of completion. The certificate should then be saved as a PDF via “Print to PDF” and a copy of the certificate should be sent to grantsoffice@union.edu.

Training Renewal

Senior/key personnel on funded NIH awards will be required to complete the training annually. At this time, senior/key personnel on funded NSF awards will only be required to renew their training prior to the submission of a new proposal.

In order to renew their training, trainees will need to select the checkbox for beginning a new attempt of the training before re-entering the course. Upon completion of their renewal training, trainees will need to enter their name on the certificate of completion. The certificate should then be saved as a PDF via “Print to PDF” and a copy of the certificate should be sent to grantsoffice@union.edu.