U.S. Department of Agriculture (USDA)

See: USDA General Terms and Conditions for Federal Awards (Dec. 2025) and Deviation # 2026-USDA-0001-F (Jun. 2026)

Covered Individuals* at USU on an Active USDA Award to US

*USDA defines a covered individual as:

  1. An individual who meets both of the following criteria:
    1. Contributes to the scientific development or execution of research, carried out as part of this USDA award, through any of the following responsibilities:
      1. Directing the overall scientific direction of the project;
      2. Designing or critically evaluating key experiments or methodologies;
      3. Interpreting primary research data or results;
      4. Serving as a primary or senior author on publications resulting from the project;
      5. Exercising direct supervisory authority over research personnel working on the research project; or
      6. Generating, handling, or having direct access to primary, pre-publication research data; proprietary materials; or critical, specialized methodologies essential to the project’s execution.
    2. Is a principal investigator (PI), other senior or key personnel, or a researcher (including undergraduate, graduate, and postdoctoral students) who is not a USDA employee; or
  2. Any other individual who USDA specifically identifies in writing as a covered individual.

Requirement: Covered individuals at USU on an active USDA award to USU must complete Research Security Training every 12 months.

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: If you are identified by Sponsored Programs as a covered individual on an active USDA award to USU as of January 2026, you will be notified to complete Research Security Training in Learn Blue by February 2026. At this time, it is unclear whether and how USDA will certify training completion for personnel on active USDA awards.

Retraining: After initial completion of Research Security Training, you will be automatically notified by Learn Blue to retake Research Security Training every 12
months. If by this time you are not on an active USDA award and are not considering applying for further USDA funding, you can test out of the training in Learn Blue.

Covered Individuals at USU on a Proposal to USDA

Requirement: At the time of submitting a proposal in Kuali, personnel employed by USU who appear on a proposal to USDA must certify that they have completed Research Security Training within 12 months of proposal submission.

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: If you are identified by Sponsored Programs as a covered individual on a proposal submission in Kuali, you will be notified to complete Research Security Training in Learn Blue. You will then certify to USDA, on the appropriate form(s) in SciENcv, that you have completed Research Security Training within 12 months of the date of application submission.

Retraining: After initial completion of Research Security Training, you will be automatically notified by Learn Blue to retake Research Security Training every 12 months. If by this time you are not on an active USDA award and are not considering applying for further USDA funding, you can test out of the training in Learn Blue.

Non-USU Covered Individuals (Including Subrecipients) on a USU Proposal to USD

Requirement: Covered individuals (including subrecipients) employed by a non-USU institution to work on an active USDA award to USU must complete Research Security Training every 12 months.

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: This requirement will be communicated to non-USU covered individuals and subrecipients through USU’s Subrecipient Commitment Form.

See: USDA General Terms and Conditions for Federal Awards (Dec. 2025) and Deviation # 2026-USDA-0001-F (Jun. 2026).

Covered Individuals* at USU on a Proposal to USDA

*USDA defines a covered individual as:

  1. An individual who meets both of the following criteria:
    1. Contributes to the scientific development or execution of research, carried out as part of this USDA award, through any of the following responsibilities:
      1. Directing the overall scientific direction of the project;
      2. Designing or critically evaluating key experiments or methodologies;
      3. Interpreting primary research data or results;
      4. Serving as a primary or senior author on publications resulting from the project;
      5. Exercising direct supervisory authority over research personnel working on the research project; or
      6. Generating, handling, or having direct access to primary, pre-publication research data; proprietary materials; or critical, specialized methodologies essential to the project’s execution.
    2. Is a principal investigator (PI), other senior or key personnel, or a researcher (including undergraduate, graduate, and postdoctoral students) who is not a USDA employee; or
  2. Any other individual who USDA specifically identifies in writing as a covered individual.

Requirement: Any person who has been party to a Malign Foreign Talent Recruitment Program (MFTRP) within 10 years is not eligible to submit a proposal to USDA. At the time of submitting a proposal, covered individuals who appear on a USU proposal to USDA must certify that they are not party to any MFTRP.

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: If you are identified by Sponsored Programs as a covered individual on a proposal submission in Kuali, you will certify to USDA, on the Common Form for Current and Pending (Other) Support and Common Form for Biographical Sketch forms in SciENcv, that you have not been party to an MFTRP within 10 years.

Recertification: After initial MFTRP certification to USDA in SciENcv, USDA may prompt you to submit an annual recertification for the duration of the award.

USU Office of Research

Requirement: USU must provide training on the risks of MFTRPs to covered individuals.

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: The Research Security Training required for covered individuals on USDA awards to USU includes content that adequately addresses the risks of MFTRPs.

See: USDA General Terms and Conditions for Federal Awards (Dec. 2025) and Deviation # 2026-USDA-0001-F (Jun. 2026)

Covered Individuals* at USU on a Proposal to USDA

*USDA defines a covered individual as:

  1. An individual who meets both of the following criteria:
    1. Contributes to the scientific development or execution of research, carried out as part of this USDA award, through any of the following responsibilities:
      1. Directing the overall scientific direction of the project;
      2. Designing or critically evaluating key experiments or methodologies;
      3. Interpreting primary research data or results;
      4. Serving as a primary or senior author on publications resulting from the project;
      5. Exercising direct supervisory authority over research personnel working on the research project; or
      6. Generating, handling, or having direct access to primary, pre-publication research data; proprietary materials; or critical, specialized methodologies essential to the project’s execution.
    2. Is a principal investigator (PI), other senior or key personnel, or a researcher (including undergraduate, graduate, and postdoctoral students) who is not a USDA employee; or
  2. Any other individual who USDA specifically identifies in writing as a covered individual.

Requirement: Covered individuals at USU on an active USDA award to USU may not be subject to foreign ownership, control, or influence (FOCI) by the governments of China, Iran, North Korea, or Russia

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: Covered individuals must report any foreign affiliations through a USU conflict of interest disclosure and must immediately report any FOCI by the governments of China, Iran, North Korea, or Russia to the USU Sponsored Programs officer overseeing the award.

Sponsored Programs Officer Overseeing an Active Award from USDA

Requirement: Neither USU nor any covered individual on a USDA award to USU may be subject to foreign ownership, control, or influence by the governments of China, Iran, North Korea, or Russia.

In addition, USU may not enter into any subawards, contracts, or other agreements related to the USDA award, or provide any form of direct benefit (material or non-material) through work conducted under, in direct support of, or otherwise reasonably related to the award, to the governments of China, Cuba, Iran, North Korea, Russia, or Venezuela.

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: If USU discovers (such as via a finding by the Research Integrity & Compliance Office) any covered individual on an active USDA award is subject to foreign ownership, control, or influence by the governments of China, Iran, North Korea, or Russia, the USU Sponsored Programs officer overseeing the award must report the discovery to USDA within five calendar days.

See: USDA General Terms and Conditions for Federal Awards (Dec. 2025) and Deviation # 2026-USDA-0001-F (Jun. 2026)

Covered Individuals* at USU on a Proposal to USDA

*USDA defines a covered individual as:

  1. An individual who meets both of the following criteria:
    1. Contributes to the scientific development or execution of research, carried out as part of this USDA award, through any of the following responsibilities:
      1. Directing the overall scientific direction of the project;
      2. Designing or critically evaluating key experiments or methodologies;
      3. Interpreting primary research data or results;
      4. Serving as a primary or senior author on publications resulting from the project;
      5. Exercising direct supervisory authority over research personnel working on the research project; or
      6. Generating, handling, or having direct access to primary, pre-publication research data; proprietary materials; or critical, specialized methodologies essential to the project’s execution.
    2. Is a principal investigator (PI), other senior or key personnel, or a researcher (including undergraduate, graduate, and postdoctoral students) who is not a USDA employee; or
  2. Any other individual who USDA specifically identifies in writing as a covered individual.

Requirement: Covered individuals must disclose to USDA all foreign appointments, employment with a foreign entity, participation in a foreign talent recruitment program (FTRP), and any other requested information.

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: If you are identified by Sponsored Programs as a covered individual on a proposal submission in Kuali, you will disclose to USDA, on the Common Form for Current and Pending (Other) Support and Common Form for Biographical Sketch forms (known together as the Common Forms) in SciENcv, all foreign appointments, employment with a foreign entity, participation in a foreign talent recruitment program (FTRP), and any other information as requested on the forms.

Recertification: After initial disclosures to USDA in SciENcv, USDA will prompt you to submit a recertification of the Common Forms disclosures on at least an annual basis for the duration of the award.

Non-USU Covered Individuals (Including Subrecipients) on a USU Proposal to USDA

Requirement: Covered individuals must disclose to USDA all foreign appointments, employment with a foreign entity, participation in a foreign talent recruitment program (FTRP), and any other requested information.

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: This requirement will be communicated to non-USU covered individuals and subrecipients through USU’s Subrecipient Commitment Form.

Sponsored Programs Proposal Analyst Submitting a Proposal to USDA

Requirement: At the time of submitting a proposal, the USU proposal analyst must provide to USDA any supporting documentation, including copies of contracts, grants, or any other agreements, specific to foreign appointments, employment with a foreign entity, participation in a foreign talent recruitment program (FTRP), and other information reported as current and pending support for all covered individuals.

The USU proposal analyst must also review the documents provided by covered individuals for compliance with USDA terms and conditions and verify that the Common Forms are certified by the covered individuals to be current, accurate, and complete.

Requirement Effective Date: June 3, 2026.

How to Complete this Requirement: USU Office of Research is in the process of determining at which stage and in what form the USU proposal analyst will provide USDA with the required supporting documentation for covered individuals’ disclosures.