Updated April 2026
Federal agencies continue to implement research security requirements established under the CHIPS and Science Act and NSPM-33. Investigators should be aware of both Research Security Training (RST) and Malign Foreign Talent Recruitment Program (MFTRP) certification requirements, which now apply to many federal funding opportunities.
Research Security Training (RST)
UCSF investigators and other covered personnel (as defined by the federal funding agency below) must complete the University of California Research Security Training before proposal submission when required by the sponsoring agency.
NIH Applications
Effective for NIH applications due on or after May 25, 2026, all individuals meeting the NIH definition of Senior/Key Personnel (SKP) must certify completion of Research Security Training within the 12 months prior to application submission NOT-OD-26-017.
NIH Clarification on Who Must Complete Training
NIH has clarified that the requirement applies only to individuals who meet the definition of Senior/Key Personnel.
The following generally do not require RST certification unless they are designated as Senior/Key Personnel:
- Other Significant Contributors (OSC) – confirmed by NIH
- Mentors on K awards—OSR’s interpretation of the guidance
- Participating Faculty on Training Grants
The inclusion of a biosketch alone does not trigger the RST requirement.
UCSF Process Update
To reduce administrative burden:
- Faculty and Senior/Key Personnel are no longer routinely required to submit training diplomas/completions to OSR.
- OSR will verify completion through a secure report from the UC Learning Center.
- In limited circumstances, investigators may be asked to provide proof of completion.
What You Need to Do
- Complete UC Research Security Training prior to proposal submission.
- 12 months prior for NIH and NSF
- Continue to certify training completion when required by agency proposal systems, sponsor forms, and certifications.
Training completed on or after September 23, 2025, satisfies both the NIH Research Security Training requirement and NIH Other Support training requirements.
Malign Foreign Talent Recruitment Program (MFTRP) Certifications
Several federal agencies now require certifications that covered individuals are not participating in a Malign Foreign Talent Recruitment Program. MFTRP certifications are typically completed during proposal submission and may be required for investigators and other covered individuals, depending on agency requirements.
Current Federal Agency Requirements
| Agency | Research Security Training | MFTRP Certification |
| Department of Energy (DOE) | Required for covered individuals within 12 months from the time an application for DOE funding is submitted | Required |
| National Aeronautics and Space Administration (NASA) | Required for covered individuals; covered individuals must certify that they have taken the required research security training within 12 months prior to a proposal submission or at the time they are added to an award that has already been issued. | Required |
| National Institutes of Health (NIH) | Required for Senior/Key Personnel within 12 months of the date of application submission. | Required |
| National Science Foundation (NSF) | Required for Senior/Key Personnel listed on an NSF proposal submitted on or after December 2, 2025. | Required |
| U.S. Department of Agriculture (USDA) | Required for Senior/Key Personnel either at the time of application, where applicable, or within the 12-month period immediately preceding the commencement of work on the award. | Required |
| Department of Justice (DOJ) | Agency implementation guidance pending. | Not currently required |
| Department of Defense (DOD) | Agency implementation guidance pending. | Not currently agency-wide |
Resources
- UCSF Research Security-Related Regulations by Federal Agency
- NIH Research Security Training Instructions
- NIH Other Support Guidance
- NIH Biographical Sketch Guidance