Federal Research Security Reporting and Certification Requirements

(Updated February 2026)

While USU Sponsored Programs will coordinate with USU researchers to make sure they comply with the applicable requirements at the time of proposal submission and during a project, researchers should review this resource to anticipate the requirements that apply to them.

Summary of Requirements

Agency	Requirement Type	Who It Applies To	Effective Date	Requirement Summary
NSF	Research Security Training	Senior/key personnel (see NSF page for definition) on active awards & proposals	Dec. 2, 2025	Complete Research Security Training within 12 months of proposal submission and complete annual retraining for the duration of the award.
	Research Security Training	Sponsored Programs Proposal Analyst	Dec. 2, 2025	Certify at proposal submission that all senior/key personnel have completed Research Security Training within the prior 12 months.
	MFTRP Certification	Senior/key personnel on active awards & proposals	May 20, 2024	Certify non-participation in a Malign Foreign Talent Recruitment Program at proposal submission and annually for active awards.
	MFTRP Certification	Sponsored Programs Proposal Analyst	Dec. 2, 2025	Certify at proposal submission that all senior/key personnel have completed MFTRP certifications.
	Confucius Institute Certification	Sponsored Programs Proposal Analyst	Dec. 2, 2025	Certify at proposal submission that institution does not host a Confucius Institute.
	Foreign Financial Disclosure Reporting	Sponsored Programs Proposal Analyst	Aug. 9, 2022	Report annually current foreign financial support totaling $50,000 or more received during the reporting period.
NIH	Research Security Training	Senior/key personnel (see NIH page for definition) on active awards & proposals	July 17, 2025 or May 25, 2026	Complete Research Security Training and annual retraining addressing disclosure of Other Support and foreign activities.
	Research Security Training	Sponsored Programs Proposal Analyst	May 25, 2026	Certify at proposal submission that each covered individual has completed Research Security Training.
	MFTRP Certification	Senior/key personnel on proposals	Jan. 25, 2026	Certify at proposal submission non-participation an MFTRP.
	MFTRP Certification	Senior/key personnel on active awards	Jan. 25, 2026	Recertify annually on the RPPR non-participation in an MFTRP.
	MFTRP Certification	Sponsored Programs Proposal Analyst	Jan. 25, 2026	Certify at proposal submission that each covered individual has completed Research Security Training.
USDA	Research Security Training	Covered individuals (see USDA page for definition) on active awards & proposals	Dec. 31, 2025	Complete Research Security Training and recertify annually for the duration of the award.
	MFTRP Certification	Covered individuals on active awards & proposals	Dec. 31, 2025	Certify non-participation in a Malign Foreign Talent Recruitment Program at proposal submission and annually for the duration of the award.
DOE	Research Security Training	Covered individuals (see DOE page for definition) on active awards & proposals	May 1, 2025	Complete Research Security Training within 12 months of proposal submission and annually for active awards.
	Research Security Training	Sponsored Programs Proposal Analyst	May 1, 2025	Certify at proposal submission that all covered individuals have completed Research Security Training within 12 months of proposal submission.
	MFTRP Certification	Covered individuals on proposals	2025	Certify at proposal submission non-participation in an MFTRP.
	MFTRP Certification	Sponsored Programs Proposal Analyst	2025	Certify at proposal submission institutional compliance with MFTRP prohibitions.
	Transparency of Foreign Connections Disclosure	Sponsored Programs Proposal Analyst	2025	Disclose foreign relationships, affiliations, and activities upon DOE request and update disclosures when information changes.
	Entity of Concern Prohibition Disclosure	Sponsored Programs Proposal Analyst	Aug. 13, 2024	Certify that no project participants are entities of concern.
NASA	Research Security Training	Covered individuals (see NASA page for definition) on active awards & proposals	Aug. 5, 2026	Complete Research Security Training within 12 months of proposal submission and annually for active awards.
	Research Security Training	Sponsored Programs Proposal Analyst	Aug. 5, 2026	Certify at proposal submission that all covered individuals employed by USU have completed Research Security Training within 12 months of proposal submission.
	MFTRP Certification	Covered individuals on proposals	Mar. 21, 2025	Certify at proposal submission non-participation in an MFTRP and annually for active awards.
	MFTRP Certification	Sponsored Programs Proposal Analyst	Mar. 21, 2025	Certify at proposal submission institutional compliance with MFTRP prohibitions.