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Research Security Training

Background

The federal government is requiring research security training for covered individuals receiving or applying for federal funding. This mandate stems from President Trump’s National Security Presidential Memo-33 (2021) and the CHIPs and Science Act (2022). To ensure compliance among all federal agencies, Northwestern will require all principal investigators and senior/key personnel working on a federal award or submitting a proposal to a federal agency, to complete this training by October 1, 2025.

A covered individual is defined as someone who significantly contributes to a federally funded research project's development or execution and is designated as such by the federal research agency, requiring them to complete research security training. 

Roles & Responsibilities

  • Principal Investigators are responsible for determining which personnel meet the criteria of a covered individual.
  • Research Administrators are responsible for verifying compliance prior to submission of federal application or award materials to sponsored research for review.
  • Sponsored Research is responsible for verifying compliance prior to submission of federal applications and acceptance of awards. 

Training Verification & SR Actions 

Training for covered individuals is required to be completed and must be verified by both the RA and SR prior to: 

  • Proposal submission 
  • JIT  
  • Award receipt
  • RPPR / Continuation submissions 
  • Personnel change requests 
  • Addition of new subawards 

If training has not been completed as per sponsor requirements, Sponsored Research will not take further action. For example,

  • SR will not submit applications if training for covered individuals is not complete; certification of compliance is done when the proposal is submitted. 
  • SR will hold award setup until training for covered individuals is complete; certification is likely to be required by execution of the award or spending/draw-down occurs. 

Verification of compliance will occur across the lifecycle of the project. Refer to Research Security Training Verification Guidance for additional information. 

Resources