Research Security Training Requirement

More information on the Research Security Training Requirement can be found in DOE's Financial Assistance Letter (FAL) on this topic: (FAL 2025-02) Financial Assistance Letter Research Security Training Requirements for all R&D Financial Assistance Awards | Department of Energy.

NSF, in partnership with the National Institutes of Health (NIH), the Department of Energy (DOE) and the Department of Defense (DOD), have provided four online research security training (RST) modules as a resource to awardee organizations. Subsequently, the SECURE Center developed an updated and condensed version of the four modules. The condensed RST module is designed to meet the government-wide RST requirement in Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234). To that end, DOE recognizes completion of the condensed module developed by the SECURE Center as compliant with its RST requirements.  

FAQs for Applicants: Research Security Training Requirement

Question: My institution wants to use our own research security training. How do I get this training approved by DOE?

Answer: Research security training developed by institutions/organizations does not require review and approval by federal agencies. The legal requirements for research security training are for covered individuals and applicant organizations to “certify that covered individuals have completed within one year of such application research security training” that meets the requirements under 42 USC 19234(c). 

Question: How should DOE/NNSA Laboratory employees who are included in Notice of Funding Opportunity (NOFO) applications fulfill the Research Security training requirement?

Answer: To fulfill the Research Security training requirement, the National Laboratories may utilize the consolidated training module developed by the SECURE Center or develop and implement their own research security training aligned with the requirements under 42 USC 19234, which lists the following topics:

• cybersecurity,
• international collaboration and international travel,
• foreign interference, and
• rules for proper use of funds, disclosure, conflict of commitment, and conflict of interest

The National Laboratories will need to certify that covered individuals have been appropriately trained on content that meets the guidelines in 42 USC 19234, but the training itself is not legally subject to agency review/approval.

DOE acknowledges that the National Laboratories have well-established training practices in place that may already meet the criteria for research security training under 42 USC 19234, including on export control, counterintelligence, conflict of interest/conflict of commitment, and other topics. 

In addition to the 42 USC 19234 requirements described above, forthcoming NSPM-33 Research Security Program requirements may necessitate additional research security training topics in the future, such as risk mitigation, malign foreign talent recruitment programs, and export control. DOE is working to identify any potential gaps and will incorporate any unmet externally-driven requirements into the appropriate DOE Order(s) and Contractors Requirement Document(s). 

Question: Does the training certification requirement apply to DOE/NNSA national laboratory employees and/or people who have “joint appointments” at a university and a DOE/NNSA national lab?

Answer: Yes. Training for covered individuals (including financial assistance and DOE/NNSA national lab covered individuals) is in 42 USC 19234, and certification is required.  While DOE Order 486.1A is being updated to include the training requirement, lab employees who are listed as covered individuals on an application to a NOFO are required to submit the current and pending support form as well as the training certification.

Question: Does the training certification requirement apply to people who are employees of other federal agencies?

Answer: The training requirement for federal employees is in NSPM-33 (Sec. 4(f); certification not expressly required). If a federal employee is a covered individual on an application to a NOFO, they should follow their home agency training requirements.  

Question: What verification is needed to ensure the content of an independently developed training program satisfies the Section 10634(b) requirements?

Answer: The organizational certification provided by the recipient confirms compliance with Section 10634(b) requirements. As stated in the NOFO provision and award term on this topic, DOE applicants who receive an award must maintain sufficient records of their compliance and records must be made available to DOE upon request.