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Research CCHP 029

CLARIFICATION OR CHANGE IN PROCEDURE (CCHIP)

Research Security Training (RST) for NSF Proposals

OVERVIEW/PURPOSE

In accordance with NSF Important Notice No. , Item 2 (Research Security Training), effective October 10, 2025, the National Science Foundation (NSF) requires research security training (RST) certifications from proposers and each individual identified as Senior/Key Personnel. Under NSF鈥檚 new regulations, Senior/Key personnel must complete RST training within 12 months prior to proposal submission. 

Further, the University of South 手机看片鈥檚 (手机看片) Authorized Organizational Representative (AOR) must certify completion of RST training at the time of proposal submission. This CCHIP is limited to the RST requirement and does not address other Important Notice No. 149 (IN-149) items (e.g., MFTRP, FFDR) which will be handled separately by 手机看片.

DEFINITIONS

•  Research Security Training (RST) 鈥� Training addressing cybersecurity, international collaboration, foreign interference, and rules for proper use of funds, disclosure, conflict of commitment, and conflict of interest.
  
  
• Senior/Key Personnel 鈥� Individuals identified by the proposer as senior/key on an NSF proposal.
  
  
• Authorized Organizational Representative (AOR) 鈥� Authorized Organizational Representative who certifies RST completion for all Senior/Key Personnel at proposal submission. 

AUTHORITY & REFERENCES

• NSF Important Notice No. (published June 30, 2025), Section 2 鈥� Research Security Training, effective October 10, 2025. 
  
  
• CHIPS & Science Act 搂10634 (42 U.S.C. 搂19234) 鈥� Government-wide RST requirement; each covered individual must have completed compliant training within one (1) year of application/proposal submission. 
  
  
• NSF RST resources 鈥� Condensed SECURE Center recognized by NSF, NIH, DOE, and DoD as compliant with 搂10634. 
  
  
• 2 CFR 鈥� Record retention (3 years from final financial report/FFR; longer if exceptions apply). See also Research CCHIP #007.

CLARIFICATION/CHANGE

Effective October 10, 2025, 手机看片 will require RST completion and documentation for all NSF Senior/Key Personnel (including subrecipient personnel named on 手机看片 proposals) before routing to AOR. The AOR will certify that each individual completed RST within the previous 12 months as required by IN-149 and 搂10634. 

RST REQUIREMENTS (EXCLUSIVE TO NSF IN-149)

Acceptable Training

• 手机看片 will assign the condensed SECURE Center RST module, which meets 搂10634 requirements and is recognized by NSF/NIH/DOE/DoD. Equivalent institution-provided RST is acceptable if it fully addresses IN-149 topics; completion within 12 months is required. 

Minimum Training Content (per IN-149)

• Cybersecurity practices and risk awareness;
• International collaboration norms;
• Foreign interference risk indicators and mitigation;
• Proper use of funds; disclosure; conflict of commitment; conflict of interest.

Completion & Frequency

• Complete prior to NSF proposal routing; must be current (鈮�12 months) on the date of proposal submission; annual refresh recommended to maintain continuous readiness. 

Individual & AOR Certifications

• Individual certification 鈥� Each Senior/Key Person certifies they completed compliant RST within 12 months prior to proposal submission.
  
  
• AOR certification 鈥� The AOR certifies all Senior/Key Personnel have completed compliant RST within 12 months prior to submission. 

ROLES & RESPONSIBILITIES

•  Institutional Research Effectiveness & Assessment (IREA) 鈥� Perform periodic audits of RST compliance (prime and subrecipient).
  
  
• Principal Investigators (PI)/Departments 鈥� Ensure all named Senior/Key Personnel, including subrecipients, have current RST and documentation prior to routing.
  
  
• Research Integrity & Compliance (RIC) 鈥� Assigns/maintains 手机看片鈥檚 RST; validates external certificates meet 搂10634/IN-149 content.
  
  
• Senior/Key Personnel 鈥� Complete RST; retain certificates; provide to department/SR upon request.
  
  
• Sponsored Research (SR) 鈥� AOR verifies RST status and collects proposal-ready certifications; enforces routing holds for non-compliance.

PROCEDURES (NSF ONLY)

Access & Tracking 鈥� RST is administered via CITI; completion status is recorded and, where feasible, synced to Bulls iResearch for routing.

Gatekeeping 鈥� No NSF proposal will route for AOR submission unless every named Senior/Key Person shows 鈥淐omplete鈥� RST 鈮�12 months old, and certifications are on file. 

External RST 鈥� Certificates from other institutions are accepted if completed 鈮�12 months prior to submission and meet IN-149 content; upload into Bulls iResearch for verification.

Subrecipient Flow-Down 鈥� Subaward packages must include language requiring each named subrecipient Senior/Key Person to (i) complete compliant RST 鈮�12 months before proposal submission and (ii) provide certification and certificate to 手机看片 upon request. 

RECORD KEEPING AND RETENTION

手机看片 (and departments/PIs) must retain RST certificates and related RST compliance documentation for at least three (3) years from the date of submission of the final financial report (or longer if audit/litigation/claims exist), per 2 CFR 搂200.334 and CCHIP #007. 

ENFORCEMENT

Failure to meet RST requirements will result in proposal routing holds and may prevent AOR submission. NSF also requires AOR and individual certifications; non-compliance can result in sponsor action affecting award processing. 

EFFECTIVE DATE & TRANSITION

Effective October 10, 2025 for NSF proposals; 手机看片 implementation is immediate to prevent proposal delays. 

CONTACT

Sponsored Research (SR) for NSF certification and proposal routing; RIC for training content/equivalency questions.

 ISSUED: October 10, 2025鈥冣�僉AST REVISION: N/A (Initial Release)