Required training on research security for federal funding

Dear colleagues,

As a result of changes to U.S. federal agencies’ research funding requirements, MIT will now require all principal investigators (PIs), co-PIs, and other senior/key personnel engaged in federally funded research (“covered individuals”) to complete research security training by December 31, 2025. In addition, if you plan to apply for funding from the National Institutes of Health (NIH), the National Science Foundation (NSF), or the Department of Energy (DOE), you should make plans now to complete the training ahead of those agencies’ earlier deadlines, which are approaching quickly. Below, you will find details on how to access MIT’s training modules and meet the requirement this fall.

Federal funders’ training requirements

Research security training is an outcome of National Security Presidential Memorandum-33 (NSPM-33), issued in 2021, and the 2022 CHIPS and Science Act. Several federal agencies have instituted policies requiring the training. Because we anticipate this requirement will soon be instituted by all award-issuing federal agencies, MIT expects all federally funded covered individuals to complete the training by December 31, 2025 — or sooner as required by the agencies — to ensure compliance.

Agency-specific deadlines this fall

Going forward, proposals due on or after each of the dates below will not be accepted by MIT Research Administration Services (RAS) unless the covered individuals have completed the training within the past 12 months. In effect, the training must be completed at least 5 full business days prior to the proposal deadline. In some cases this will require quick action.

• DOE: As shared this past spring with DOE-funded PIs, effective May 1, 2025, the DOE already requires covered individuals to certify completion of the research security training at the time of application, award, or award modification. The additional requirement described above will apply to proposals that are due to DOE on or after October 1, 2025.
   
• NIH: Beginning on October 1, 2025, the NIH will require senior/key personnel to complete training on the “requirement to disclose all research activities and affiliations (active and pending) in Other Support.” This requirement can be fulfilled by completing MIT’s research security training.
   
• NSF: Beginning on October 10, 2025, NSF will require senior/key personnel to certify completion of research security training at the proposal stage and at the time of a new award or modification.

Please contact your RAS contract administrator or ra-help@mit.edu with any questions about these deadlines. If additional federal agencies announce training deadlines that fall earlier than year-end, researchers with active awards or proposals in development will be notified, as applicable.

How to meet the requirement

MIT has developed four web-based Research Security Training modules that are specifically tailored for MIT researchers. The training will take approximately 90 minutes to complete and will fulfill your research security training obligation.

In addition to the proposal deadlines outlined above and the December 31 deadline for all federally funded researchers at MIT, covered individuals who are expecting a new award, or award modification, from the NIH, NSF, or DOE are also encouraged to take the training as soon as possible in order to certify completion of the training at the time of award.

If you have already completed MIT’s training, no action is required. If you have already completed research security training provided by NSF or another research institution that specifically fulfills the federal requirement, you may submit your certificate of course completion to ra-help@mit.edu to receive credit in our system of record.

Accessing the training

You can access the training modules in the Atlas Learning Center (Touchstone login required). If they do not already appear as required courses on your “My Training Needs” page, please join the Atlas training group for this required training or contact ra-help@mit.edu.

Thank you for your attention to this important matter.

Sincerely,

Ian A. Waitz
Vice President for Research