Research security training FAQ

• Why is research security training (RST) required?
  Federal grant recipients must complete research security training (RST) as required by National Security Presidential Memorandum-33 (NSPM-33) and the CHIPS and Science Act of 2022.  Personnel must complete the RST within one year of an award application and certify its completion.  
• Who needs to complete the RST?

  All “covered individuals” including: 

  • Principal investigators (PIs). 

  • Co-PIs. 

  • Senior/key personnel listed on a research and development award application. 

  • Subrecipient senior/key personnel named in the proposal. 

  • New individuals added to a project - must complete the training within 30 days of joining . 
• What does RST cover?

  RST topics include: 

  • Cybersecurity: protecting research data and systems.

  • Foreign Influence: recognizing and mitigating risks from undue foreign influence. 

  • Disclosure: requirements for disclosing funding and potential conflicts of interest. 

  • Intellectual Property: proper management and use of intellectual property. 

  • International Collaboration: promoting responsible international collaboration . 
• Is the RST required before proposal submission or only before an award is issued? 
  Per federal regulations, DOE, NSF, and USDA require the training to be completed not more than 12 months before the application submission date. For consistency, K-State requires that the training be completed within 12 months of application submission for all sponsors, regardless of the sponsor type. As we work toward compliance, DOE (5/1/25-forward) and NSF (10/10/25-forward) proposals cannot be submitted until all named senior/key personnel have completed RST within the past 12 months. For other sponsors, K-State requires completion by award at the latest. The RST must be completed by the award stage for the award to be processed to SPA for FIS account set up. This is similar to other required trainings (ECR, RCR, Export Control, IACUC, IRB, etc.). 
• Is K-State applying the RST requirement universally across all projects for consistency, or only to those subject to the federal mandate? 
  Yes, K-State is applying this requirement to all application submissions, both federal and non-federal. 
• The RST currently takes 2–4 hours for faculty. Is this expected annually?

  The mandate specifies a 12-month cycle, i.e. annual training, throughout the duration of the project. The training must be completed within the 12 months prior to the application submission and repeats annually for the award duration.  

  The RST is available through the CITI webpage.  CITI has several RSTs including two four-hour versions; however, K-State and the federal funding institutions only require the shorter, one-hour training titled "Research Security Training (Combined)."  Any RST questions can be directed to Research Security Officer Murry Streetman at mtstreetman@k-state.edu or the Office of Research Integrity, Compliance, and Security at comply@k-state.edu. 

• Is there guidance for grant specialists managing subawards on federal projects? The RST requirement is not reflected in the current subrecipient form. 
  Subrecipients shall ensure that all senior/key personnel listed on the Federal R&D application (and those subsequently added) have completed RST within 12 months prior to the application date, and that individuals added after award complete RST within 30 days of joining the project (or earlier if required by the sponsor), with annual refresh thereafter, consistent with 42 U.S.C. § 19234(c) and any sponsor-specific guidance (e.g., DOE FAL 2025-02; NSF Important Notice 149; NIH forthcoming2). Subrecipients shall retain documentation and provide evidence upon request. Failure to comply constitutes non-compliance subject to remedies in 2 CFR 200.339, including withholding or termination of the subaward. The KSU Subrecipient Commitment Form is being updated and will be released soon. 
• Should subrecipients on non-federal projects also be asked to complete RST to maintain internal consistency, even if not federally required? 
  To avoid confusion and opposing guidance, we are working to clarify a few more situations with ORICS before providing firm guidance on this. It is anticipated that subrecipients will only be required to certify compliance with Section 10634(b) of Public Law 117-167 (CHIPS and Sciences Act). K-State will not dictate a subrecipient's compliance approach, but will rather, require them to certify compliance.