Memo: New Research Security Training Requirement for DOE-Sponsored Investigators To Be Completed by May 1, 2025 and for All Other Researchers to Be Completed by June 30, 2025

Research Security Training Background

National Security Presidential Memorandum-33 (NSPM-33), issued in January 2021, requires institutions of higher education awarded greater than $50 million per year in total federal research funding to certify that they have a research security program and lists research security training as one of four elements of a research security program. Codifying NSPM-33, the CHIPS and Science Act of 2022 mandates that a research security program include implementation of research security training for all covered individuals listed on applications for federal research and development (R&D) funding and requires research institutions to certify that all covered individuals on an application have completed training.

Department of Energy (DOE) and National Nuclear Security Administration (NNSA) Deadlines

Although other federal agencies are expected to follow suit, DOE is the first agency to implement a research security training requirement for all covered individuals on a DOE project and to complete research security training before a proposal can be submitted as of May 1, 2025. To meet this requirement, Boston University must now require that all “covered individuals” on DOE projects, active or to be proposed as of May 1, 2025, complete research security training prior to May 1, 2025. 

Who is a “covered individual”?

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; 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, or key personnel and any individual regardless of title that is functionally performing in one of these named roles. 

What is the required training to be completed?

Boston University has adopted the Collaborative Institutional Training Initiative (CITI) Program’s Research Security Training (Combined) course to meet the DOE training requirement. The four-module training takes approximately one hour and covers an introduction to research security, the importance of disclosure, risk mitigation and management and international collaboration. 

How will a PI prove completion of research security training by all covered individuals?

An individual’s completion record is available to them in CITI and should be emailed or printed and provided to the PI of the proposal. PIs should maintain completion certifications in the event they are requested by DOE. In addition, when submitting a Proposal Summary Form, PIs will be required to certify that all covered individuals on a project have completed research security training within one year prior to the submission of the proposal.

All other covered individuals who engage in or propose to engage in sponsored research, including non-federal and industry-sponsored research, must complete the CITI research security training by June 30, 2025. Those who have not completed the training by then will not be allowed to submit new proposals.

To complete the CITI research security training course, follow these steps:

• Access the CITI website.
• Log in to your existing CITI account or register if this is your first time visiting CITI
• To access the research security training, you must affiliate with the Boston University CRC campus. Note that in CITI you may be affiliated with other institutional accounts, such as BUMC, however the training is only available via the CRC training portfolio
• When you select an email address for your registration, please use your BU email address (this enables your training certifications to connect with other University systems, such as Huron)
• Under ‘Learner Tools…’ choose ‘Add a Course’
• Under ‘Getting Started’ select ‘Research Security’
• Under ‘Research Security Curriculum’, select ‘Research Security Training (Combined)’ This will add the course to your ‘Courses Ready to Begin’
• Next, click ‘Start Now’ and take the course!

Thank you for your attention to this new requirement. Your compliance is greatly appreciated.

For more information, please see the frequently asked questions.

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