Overview
Certain federal sponsors require annual completion of Research Security Training (RST) by all covered individuals, those who play a substantive and meaningful role in developing or executing the project scope. At a minimum, this applies to all personnel designated as Senior/Key Personnel, including (but not limited to) the Principal Investigator/Project Director (PI/PD) and any Co-Principal Investigator/Project Director (Co-PI/Co-PD).
The federal research security training requirement stems from National Security Presidential Memorandum-33 (NSPM-33) and the CHIPS and Science Act (Section 10634) and is implemented through sponsor policies. These training-related certifications may be in addition to agency-specific annual certifications for covered personnel to indicate they are not party to a malign foreign talent recruitment program (MFTRP).
More information: Protecting Your Research: What You Need to Know About Malign Foreign Talent Programs
References to Federal Regulations: NSPM-33 | CHIPS and Science Act (H.R. 4346)
What federal agencies have implemented this requirement?
Federal agencies have implemented RST requirements on different timelines and may require individuals to certify completion at proposal, award, or annually during the period of performance. However, at this time USC has implemented the requirement to complete the training for all below federal agencies to ensure that we are in compliance.
- Department of Energy (DOE) — DOE requirement information
- National Science Foundation (NSF) —NSF Important Notice 149
- National Institutes of Health (NIH) —NIH notice (NOT-OD-25-069)
- S. Department of Agriculture (USDA) —USDA Secretary’s Memo SM 1078-014 (PDF)
Who is required to complete the training?
RST is required for:
- Covered Individuals, including all Senior/Key Personnel (PI/PD, Co‑PI/Co‑PD)
- Any researcher who contributes in a substantive, meaningful way to the scientific development or execution of a federally funded project subject to this requirement
This requirement applies to both USC personnel and personnel at outgoing subaward institutions.
How often is the training required?
The training must be in place prior to proposal submission and/or award set-up and completed annually (within the prior 12 months) thereafter.
How do I complete this training?
1. Log in to TrojanLearn (log in)
2. Search for “Research Security Training”
3. Launch and complete the course
⏱ Estimated time: approximately 70 minutes
How do I confirm if an individual has completed the required training?
Because compliance with requirements from certain federal agencies is mandatory prior to proposal submission and/or award set-up, it is essential to proactively confirm that all Senior/Key Personnel, both within USC and at outgoing subaward institutions, have completed the required training. Taking these steps early helps prevent delays in proposal submission, award set-up, or the issuance of outgoing subawards.
Confirming For USC Faculty and Staff:
1. Log in to Cayuse SP
2. Navigate to the Admin tab
3. Search for the individual’s name
4. Select Trainings and Certifications to view completed requirements
Confirming For Subrecipients:
Subawardee PI, co-PI, and senior/key personnel need to complete research security training, as does any other subaward researcher who contributes in a substantive, meaningful way to the scientific development or execution of the project.
Prior to proposal submission:
1. The proposed subrecipients should complete the Subaward Certification Form from available on the DCG Subaward page.
2. Section D of this form should be reviewed to confirm the subrecipient has answered “Yes” to both compliance questions.
This confirms all requirements are met and the proposal may proceed.
If the subrecipient chooses to provide a letter of commitment (LOC) in place of a Subaward Certification Form then the LOC must include a statement confirming the subrecipient is in compliance with RST requirements similar to:
At this time of submission, Subrecipient certifies that any applicable research security requirements of the Presidential Memorandum on U.S. Government-Supported Research and Development National Security Policy (NSPM-33), and the CHIPS and Science Act of 2022 for covered/senior/key individual(s) proposed for this project, as defined by the federal agency listed as prime sponsor, have been completed prior to submission of this application or will be completed if/when required by the federal agency.
Questions
For questions, please contact the Office of Ethics and Compliance at compliance@usc.edu.
🔗 Visit the Research Security Training Requirements webpage for additional guidance.