Research Security

Strengthening interdisciplinary and global programs is a strategic priority at the University of Delaware (UD). International collaboration enhances student education, results in increased opportunities for publication and scholarship, and keeps UD investigators on the cutting edge of their fields. These benefits result from foreign collaborators physically working on UD’s campus, collaboration in the form of providing or receiving materials from foreign entities, or receipt of payment from foreign entities. Foreign collaboration, though, could pose a risk. The activity could result in violations of University practice and policy, violations of regulations and requirements, and potential loss of funding.

FOREIGN ENTITIES ASSOCIATED ISSUES

While international collaborations may be acceptable, UD personnel are expected to disclose foreign involvement to ensure that potential issues are properly addressed and resolved. The following issues should be considered.

 

Conflicts of Interest

Controlled Unclassified Info (CUI) Procedures

Export Control

Conflicts of Interest

Controlled Unclassified Information (CUI) Procedures

Export Control

Financial Disclosures

Foreign Components

International Travel

Financial Disclosures

Foreign Components

International Travel

NASA China Certification

Office of Foreign Assets Control

NASA China Certification

Office of Foreign Assets Control

Restricted Party Screening

Research Security Training

Restricted Party Screening

Research Security Training

Research Security Training

NEW DOE SECURITY TRAINING REQUREMENTS

Effective May 1st, the U.S. Department of Energy (DOE) will require covered individuals to complete research security training prior to submitting DOE research proposals. The training requirement extends to subrecipients.

Covered Individuals. DOE defines a "covered individual" to include, at a minimum, any principal investigator (PI); project director (PD); co-principal investigator (Co-PI); co-project director (Co-PD); project manager; and any individual regardless of title that is functionally performing as a PI, PD, Co-PI, Co-PD, or project manager. The DOE may expand this list of designated roles to include other technical staff (such as postdocs and grad students), as specified in the applicable Notice of Funding Opportunity (NOFO) and/or terms and conditions of the award.

Certifications. Each covered individual listed on the application must certify on their Current & Pending Support document that they have completed research security training within the preceding 12 months. Additionally, UD must certify at the time of submission that all covered individuals listed on the proposal application have completed the training.

Training. UD is utilizing CITI Program’s Research Security Training (Combined) course, a condensed version of the National Science Foundation’s more extensive research security training modules, to meet the federal training requirement. The condensed course takes approximately one hour to complete, as compared to the 4+ hours necessary to complete the extended NSF version. CITI’s combined course aligns with the requirements of Section 10634(B) of the CHIPS and Science Act of 2022 and addresses research security topics including the importance of disclosure, risk mitigation and management, and international collaboration.

Records. To comply with the federal requirement, UD must maintain records of training completion to be provided to DOE upon request. The Research Office will utilize CITI’s reporting function to verify training completion. If a covered individual completed the research security training modules on the NSF website within the past year, please email a copy of the completion certificate to Clarissa Roth at RO-Agreements@udel.edu

CITI Instructions. Guidance on establishing a CITI user profile and accessing the online training is available at the link below.  Covered individuals must enter their UD email address (@udel.edu) in the “Preferred Email” field of their CITI Profile. This field is used as a link to PeopleSoft Financials to assist the University in certifying compliance.

 

Awards. For DOE awards containing the research security training requirement, any new covered individuals at the recipient and subrecipient levels added to the project must certify they have completed the training within thirty (30) calendar days of joining the project. Covered individuals previously identified in the proposal who have already certified and completed the research security training do not need to complete it again, even if they are submitting an updated Current and Pending Support Form during the life of the award.

Other Federal Sponsors. Research security training is one of required elements of a Research Security Program under National Security Presidential Memorandum 33 (NSPM-33) to safeguard United States research and development. The CHIPS and Science Act of 2022 codified the requirement for research security training into public law. The training requirement is being implemented across all federal sponsors, and updates will be shared with UD’s research community as they become applicable.

UD’s Research Security Training Program

  • UD will utilize CITI’s Research Security Training (Combined) course across all federal sponsors.
  • UD’s bi-annual cyber security training through KnowBe4 will be required for all covered individuals.
  • Export Compliance training is required for all individuals listed on active Technology Control Plans.
  • Conflict of Interest/Conflict of Commitment training is required at the time of completing the annual Conflict of Interest Disclosure Webform for all senior/key personnel submitting proposals and/or participating on active awards.

More information about the DOE requirement can be found here.

Financial Assistance Letter 2025-02, Research Security Training Requirements for all R&D Financial Assistance Awards, can be found here.

 

For more information regarding UD Regulatory Affairs
Please direct any questions or concerns by email to Clarissa Roth, Director of Research Security or 302-831-8626.
*NOTE: The University of Delaware’s Office of General Counsel oversees all legal services for the University of Delaware. Matters pertaining to research (including research-related agreements, research-related compliance, and research-related intellectual property) may be directed to the Research Office, which will coordinate with the General Counsel’s Office, as appropriate.