Purpose
This policy’s purpose is to comply with the provisions of federal law, including 2 CFR 200, the Uniform Guidance, National Security Presidential Memorandum 33 (NSPM-33), the CHIPS & Science Act, and other relevant sponsor requirements related to research security training.
Research security refers to national security concerns surrounding research involving types of sensitive data, intellectual property, export-controlled information, and other risks. Research security is important to protect public investment in research, prevent the misuse of research data and advanced technology generated at universities by malign actors, and to protect the safety and security of employees and students traveling abroad. The federal government is focusing on areas critical to protecting the security of US research such as the disclosure of conflicts of interest and commitment, including relationships or affiliations with foreign entities, and research support provided by those entities. Federal agency partners have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding.
Scope
This policy applies to all UW-La Crosse personnel identified as "covered individuals" by federal regulations and/or applicable federal agency definitions who engage in or propose to engage in federal sponsored Research & Development (R&D) projects with the National Aeronautics & Space Administration (NASA); National Science Foundation (NSF); US Health & Human Services (HHS), including the National Institutes of Health (NIH); US Department of Agriculture (USDA); US Department of Defense (DoD) as specified for particular programs; or US Department of Energy (DOE). The policy scope may extend to include additional federal agencies as implementation plans are announced.
A covered individual is an individual who a) contributes in a substantive way to the scientific development or execution of a Research & Development (R&D) project proposed to be carried out with support from a federal agency and b) is designated as a covered individual by the federal agency concerned. The definition of covered individual can vary by federal agency or award-specific language. Generally, most agencies at minimum include all senior/key personnel as covered individuals. Additionally, covered individuals for USDA sponsored projects include all principal investigators, other senior/key personnel, and researchers including undergraduate, graduate, and postdoctoral students who are not USDA employees and contribute to the scientific development or execution of the research. Per UW System guidance, all personnel working on USDA sponsored projects, including all students, are subject to research security training requirements.
Policy
In accordance with federal regulations and agency requirements, prior to submitting a Research & Development (R&D) proposal to a covered federal agency, all UW-La Crosse personnel identified as "covered individuals" by federal regulations and/or applicable federal agency requirements must complete research security training within the 12 months preceding the proposal submission deadline.
During the course of an active, covered federal award, all covered individuals must complete research security training annually.
Covered individuals added to an existing award after the award start date must complete research security training prior to beginning work on the sponsored project.
The UWL principal investigator (PI)/project director (PD) is responsible for accurately identifying all covered individuals prior to proposal submission as well as those added to a project during the course of an active award. The PI is additionally responsible for communicating research security training requirements to all covered individuals and for maintaining an updated list of covered individuals with the UWL Office of Research & Sponsored Programs in a timely manner to enable federal research security requirements to be fulfilled.
For proposals and projects where UWL acts as the lead institution, external collaborators who meet the definition of covered individuals on covered federal proposals and sponsored projects must also comply with research security training requirements. External collaborators must provide documentation to UWL ORSP to verify training completion and may not be included in a proposal until training completion has been verified. For external collaborators joining a project after an award has been issued, they may not begin work on a project until training completion has been verified.
Supporting Information
Procedures
- Within 12 months prior to the proposal submission deadline, all UWL personnel identified as covered individuals in a covered federal proposal must self-enroll in and complete the UWL Research Security Canvas course (approximately one hour).
- Completion of the training requirement is satisfied by completing the two assignments in the Research Security Canvas course:
- Upload a copy of the Federal Research Security Training completion certificate.
- Achieve a score of at least 80% on the quiz. Individuals may take the quiz an unlimited number of times.
- Training is valid for one year.
- During the course of an active, covered federal award, all UWL personnel identified as covered individuals for the award must re-complete the UWL Research Security Training Canvas course annually.
- Covered individuals joining work on a project under an active, covered federal award must complete the UWL Research Security Training in Canvas before beginning work on the project.
- During the course of an active, covered award, the PI/PD is responsible for notifying added covered individuals of the research security training requirement and for maintaining an updated list of covered individuals with the Office of Research & Sponsored Programs.
- For proposals and projects where UWL acts as the lead institution, external collaborators who meet the definition of covered individuals must provide documentation to UWL ORSP to verify training completion a) prior to proposal submission or b) before beginning work on the project if a collaborator is added after an award has been issued. External collaborators may not be included in a proposal or added to a project until training completion has been verified with ORSP.
- For subawards, certification from the the subrecipient institution's authorized organization representative (AOR) can be used as documentation that the subrecipient's covered individuals have fulfilled the requirement.
- Alternately, covered individuals outside of UWL must complete training via the NSF Secure Center, print the completion certificate at the end of the training, and submit it to UWL ORSP to verify completion.
- Training records are maintained by the Office of Research & Sponsored Programs in accordance with the requirements of the Wisconsin Open Records Law (State Statutes 19.31 through 19.39) and federal regulations.
Resources
- COGR Matrix of Laws, Regulations, and Policies Regarding Science & Security
- UW-Madison Federal Agency Guidance Regarding Disclosures of Other Support
- NASA Research Security Training Requirement
- NIH Implementation of Research Security Policies (NOT-OD-25-154)
- NIH Pre-award & Post-award Disclosures table
- NSF Important Notice No. 149: Updates to NSF Research Security Policies
- USDA America First Memorandum for USDA Arrangements & Research Security
- US DOE Research Security Training Requirement
- NSPM-33 Implementation Guidance
Last updated: March 2026
Some content adapted with permission from UW-Madison