Department of Energy (DOE)
See: (FAL 2025-02) Financial Assistance Letter Research Security Training Requirements for all R&D Financial Assistance Awards (Oct. 2024); Research Security Training Requirement (May 2025); COGR Forum VI Adapting to Change: Policy Shifts & Research Impact (Jan. 2026).
USU Covered Individuals* on a Proposal to DOE
*DOE defines a covered individual as anyone who (a) contributes in a substantive, meaningful way to the development or execution of the scope of work of a project funded by DOE or proposed for funding by DOE, and (b) is designated as a covered individual by DOE. This designation, at a minimum, includes any principal investigator, project director, co-principal investigator, co-project director, project manager, and any individual, regardless of title, that is functionally performing any of those roles.
Requirement: At the time of submitting a proposal, senior/key personnel must have completed Research Security Training within 12 months of proposal submission.
Requirement Effective Date: May 1, 2025.
How to Complete this Requirement: If you are identified by Sponsored Programs as a covered individual on a USU proposal submission in Kuali, you will be notified to complete Research Security Training in Learn Blue. You will then certify to DOE, on the Current and Pending Support form 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 DOE award and are not considering applying for further DOE funding, you can test out of the training in Learn Blue.
Non-USU Senior/Key Personnel (Including Subrecipients) on a USU Proposal to DOE
Requirement: At the time of submitting a proposal in Kuali, non-USU senior/key personnel must have completed Research Security Training within 12 months of proposal submission.
Requirement Effective Date: May 1, 2025.
How to Complete this Requirement: This requirement will be communicated to non-USU covered individuals/subrecipients through USU’s Subrecipient Commitment Form.
Sponsored Programs Proposal Analyst Submitting a Proposal to DOE
Requirement: At the time of submitting a proposal, the USU proposal analyst submitting a proposal to DOE must certify that covered individuals employed by USU have completed Research Security Training within 12 months of proposal submission.
Requirement Effective Date: May 1, 2025.
How to Complete this Requirement: At the time of submitting a proposal, the USU proposal analyst submitting a proposal to DOE must certify, through the means specified by DOE at proposal time, that covered individuals employed by USU have completed Research Security Training within 12 months of proposal submission.
USU Covered Individuals Added to a DOE Award after Selection (Instructions for USU PIs)
Requirement: Covered individuals added to a DOE project after a USU proposal is selected must certify they have taken Research Security Training within 30 days (vs. 12 months) of being added to the project.
Requirement Effective Date: May 1, 2025.
How to Complete this Requirement: If you are the USU PI, you must immediately notify any USU covered individuals or subawardees added to the project to complete, within 30 days of being added to the project, Research Security Training in Learn Blue. The newly-added covered individuals will then certify to DOE, on the Current and Pending Support form in SciENcv, that they have completed Research Security Training within 30 days of being added to the project.
Retraining: After initial completion of Research Security Training, covered individuals 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 DOE award and are not considering applying for further DOE funding, you can test out of the training in Learn Blue.
Non-USU Covered Individuals (Including Subrecipients) Added to a DOE Award after Selection (Instructions for USU PIs)
Requirement: Covered individuals added to a DOE project after a USU proposal is selected must certify they have taken Research Security Training within 30 days (vs. 12 months) of being added to the project.
Requirement Effective Date: May 1, 2025.
How to Complete this Requirement: If you are the USU PI, you must immediately notify any non-USU covered individuals or subawardees added to the project to complete, within 30 days of being added to the project, Research Security Training via their own institution’s learning suite or the CTM Training for Individual Users provided by NSF. The newly-added covered individuals will then certify to DOE, on the Current and Pending Support form in SciENcv, that they have completed Research Security Training within 12 months of the date of application submission.
Retraining: Non-USU senior/key personnel are not subject to this retraining requirement at this time.
See: Prohibition on Malign Foreign Talent Recruitment Program Participation (2025).
Covered Individuals* on a USU Proposal to DOE
*DOE defines a covered individual as anyone who (a) contributes in a substantive, meaningful way to the development or execution of the scope of work of a project funded by DOE or proposed for funding by DOE, and (b) is designated as a covered individual by DOE. This designation, at a minimum, includes any principal investigator, project director, co-principal investigator, co-project director, project manager, and any individual, regardless of title, that is functionally performing any of those roles.
Requirement: Any covered individual party to a Malign Foreign Talent Recruitment Program (MFTRP) is prohibited from participating in DOE projects. At the time of submitting a proposal, USU covered individuals must certify that they are not currently participating in any MFTRP.
Requirement Effective Date: 2025.
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 DOE, on the Current and Pending Support form in SciENcv, that you are not currently participating in any MFTRP.
Sponsored Programs Officer Overseeing an Active Award from DOE
Requirement: USU must notify DOE if any covered individual is or is believed to be participating in an MFTRP.
Requirement Effective Date: 2025.
How to Complete this Requirement: If you are the USU Sponsored Programs officer overseeing an active award from DOE, you will report any individual who is or is believed to be participating in a MFTRP by contacting your DOE Contracting Officer/Grants Officer within five business days.
See: DOE Transparency of Foreign Connections Disclosure and Certification (May 2025); COGR Forum VI Adapting to Change: Policy Shifts & Research Impact (Jan. 2026).
Sponsored Programs Officer Overseeing an Active Award from DOE
Requirement: When requested by DOE or one of its contractors, USU must submit a Transparency of Foreign Connections (TFC) disclosure.
Requirement Effective Date: 2025.
How to Complete this Requirement: The Sponsored Programs employee submitting a TFC disclosure must follow the TFC disclosure format provided by DOE or another format that includes the same substantive information, a signature, date, and the certification statement included in DOE’s format.
USU must submit an updated TFC disclosure if any information provided on the original disclosure changes, or if DOE requests an updated disclosure as part of a continuation application for an award.
See: DOE Entity of Concern Prohibition (Aug. 2024); COGR Forum VI Adapting to Change: Policy Shifts & Research Impact (Jan. 2026).
Sponsored Programs Proposal Analyst Submitting a Proposal to DOE for $10,000,000 or More in Funding
Requirement: At the time of submitting a proposal for a DOE award for $10,000,000 or more in funding, USU must certify that no project participants constitute entities of concern.
Requirement Effective Date: August 13, 2024.
How to Complete this Requirement: The USU proposal analyst submitting a proposal to DOE for $10,000,000 or more in funding will certify to DOE at the time of proposal submission that no project participants appear on the U.S. Government’s 1260H and BIS Entity lists.
USU Proposal Analyst Adding Participants to an Active DOE Award
Requirement: At the time adding participants to an active DOE award for $10,000,000 or more in funding, USU must certify that these participants do not constitute entities of concern.
Requirement Effective Date: August 13, 2024.
How to Complete this Requirement: The USU grants officer adding participants to an active DOE award for $10,000,000 or more in funding must certify that these participants do not appear on the U.S. Government’s 1260H or BIS Entity lists.