Federal Research Security Requirements

(As of August 1, 2025)
This page will continue to be updated as we receive more information.

In accordance with the CHIPS and Science Act of 2022, the federal government is strengthening safeguards to protect research from foreign influence, cybersecurity threats, and others risks. As part of this effort, federal sponsors have begun implementing Research Security requirements for all "covered individuals" who contribute substantively to federal research projects.

Federal sponsors define "covered individuals" as senior/key personnel on a sponsored project. These requirements can include:

Completion of Research Security Training
Maintaining an ORCID iD
Certifying or disclosing that "covered individuals" are not participating in Malign Foreign Talent Recruitment Programs (MFTRP)

To meet the MFTRP requirement, FAU now requires all key personnel submitting proposals to attest in Novelution that they are not participating in a MFTRP. This attestation is mandatory for each key person, regardless of the funding source.

The below information includes guidance, definitions, and requirements which may vary by sponsor.

If a sponsor is not listed, it does not mean they do not have a requirement, please refer to sponsor solicitation or guidelines.

Definitions & Requirements by Sponsor

Department of Energy (DOE)

As of May 1 2025, DOE requires all covered individuals to:

Complete Research Security Training within 12 months prior to proposal submission.
Have an ORCID iD and include it in Current & Pending support disclosures

DOE Covered Individual Definition

An individual who (a) contributes in a substantive, meaningful way to the development or execution of the scope of work of a project proposed for funding by DOE, and (b) is designated as a covered individual by DOE.

DOE designates as covered individuals any principal investigator (PI); project director (PD); co-principal investigator (Co-PI); co-project director (Co-PD); project manager; and any individual regardless of title that is functionally performing as a PI, PD, Co-PI, Co-PD, or project manager.

DOE departmental elements will often expand this list of designated roles, as specified in the applicable Notice of Funding Opportunity (NOFO) and/or terms and conditions of the Federal financial assistance award. Status as a consultant, graduate (master’s or PhD) student, or postdoctoral associate does not automatically disqualify a person from being designated as a "covered individual" if they meet the definition in (a) above.

See: FAL Research Security Training Requirements for all R&D Financial Assistance Awards

DOE Malign Foreign Talent Recruitment Program Certification

The DOE requires full disclosure of foreign involvement in Current and Pending Support documentation and does not allow participation in Malign Foreign Talent Recruitment Programs.

All covered individuals must certify that they are not currently participating in a malign foreign talent recruitment program (MFTRP) within their Current and Pending Support.

National Science Foundation (NSF)

Effective October 10, 2025, NSF requires all covered individuals to:

Complete Research Security Training within 12 months prior to proposal submission.

NSF Covered individual Definition

Principal investigators (PIs) and other senior/key person seeking or receiving Federal research and development funding (i.e., extramural funding) and researchers at Federal agency laboratories and facilities (i.e., intramural researchers, whether or not federally employed), including Government-owned, contractor-operated laboratories and facilities.

See NSF Proposal & Award Policies & Procedures Guide (PAPPG)

NSF Research Security Training Requirements

Effective October 10, 2025, NSF requires senior/key personnel take Research Security Training. This training must be completed by all covered individuals (key personnel) prior to proposal submission to NSF.

NSF Malign Foreign Talent Recruitment Program Certification

Effective May 20, 2024, covered individuals must individually certify that they are not a party to a malign foreign talent recruitment program. The SciENcv Biographical Sketch and Current and Pending (Other) Support documents require each individual to certify that the information provided is accurate, current, and complete, and that they are not a party to a malign foreign talent recruitment program. Effective June 7, 2025, all PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov that they are not party to a MFTRP.

Training Options for Covered Individuals

FAU has added the Research Security Training module to our CITI Program training portfolio of courses. Researchers have training options available through the online CITI Program that will satisfy the research security training requirement. FAU will accept either the 4-hour Research Security Training course or the condensed 1-hour Research Security Training to satisfy the initial requirement.