National Institutes of Health (NIH)
See: NIH Announces a New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements (Jul. 2025); Research Security Training Requirements for NIH (Dec. 2025); COGR Forum VI Adapting to Change: Policy Shifts & Research Impact (Jan. 2026).
Senior/Key Personnel* on an Active NIH Award to USU
*NIH defines senior/key personnel as the program director, principal investigator, or any individual who contributes to the scientific development or execution of a project in a substantive, measurable way, and generally includes those with doctoral or other professional degrees.
Requirement: Senior/key personnel on an active NIH award must complete Research Security Training in order to understand the requirement to disclose all research activities and affiliations (active and pending) on the Other Support form.
Requirement Effective Date: July 17, 2025.
How to Complete this Requirement: If you are identified by Sponsored Programs as senior/key personnel on an active NIH award to USU as of January 2026, you will be notified to complete Research Security Training in Learn Blue by February 2026.
Non-USU senior/key personnel will receive instructions in their notification email on how to complete Research Security Training outside of Learn Blue.
Retraining for USU Senior/Key Personnel: After initial completion of Research Security Training, you will be automatically notified by Learn Blue to retake Research Security Training every 12 months.
Retraining for non-USU Senior/Key Personnel: Non-USU senior/key personnel are not subject to this retraining requirement at this time.
USU Senior/Key Personnel on a Proposal to NIH
Requirement: At the time of submitting a proposal in Kuali, senior/key personnel must certify that they have completed Research Security Training within 12 months of proposal submission.
Requirement Effective Date: May 25, 2026.
How to Complete this Requirement: If you are identified by Sponsored Programs as senior/key personnel on a proposal submission in Kuali, you will be notified to complete Research Security Training in Learn Blue. You will then certify to NIH, on the Biographical Sketch form in SciENcv, that you have completed Research Security Training within 12 months of the date of application submission.
Non-USU Senior/Key Personnel (Including Subrecipients) on a USU Proposal to NIH
Requirement: At the time of submitting a proposal in Kuali, non-USU senior/key personnel must certify they have completed Research Security Training within 12 months of proposal submission.
Requirement Effective Date: May 25, 2026.
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 NIH
Requirement: Institutions must certify that each covered individual who is both employed by USU and listed on the application has completed Research Security Training.
Requirement Effective Date: May 25, 2026.
How to Complete this Requirement: If you are the USU proposal analyst submitting a proposal to NIH, you will certify to NIH via your signature on the face/cover page of the application for funding that each covered individual who is both employed by USU and listed on the application has completed Research Security Training.
See: NIH’s Implementation of Common Forms for Biographical Sketch and Current and Pending (Other) Support for Due Dates on or after January 25, 2026 (Dec. 2025).
Senior/Key Personnel* on a Proposal to NIH
*NIH defines senior/key personnel as the program director, principal investigator, or any individual who contributes to the scientific development or execution of a project in a substantive, measurable way.
Requirement: Any person party to a Malign Foreign Talent Recruitment Program (MFTRP) is not eligible to submit a proposal to NIH.
Requirement Effective Date: January 25, 2026.
How to Complete this Requirement: You will certify to NIH on the Biographical Sketch and Current and Pending (Other) Support forms in SciENcv, that you are not party to an MFTRP.
PIs and Other Senior/Key Personnel on an Active NIH Award to USU
Requirement: Senior/key personnel must certify annually, via the Research Performance Progress Report (RPPR), to their participation or non-participation in an MFTRP.
Note: PIs and senior/key personnel do not have authority to sign on behalf of the University. However, because this certification is an individual attestation required as part of the RPPR process, each individual must sign their own certification, and these signatures are accepted for this purpose.
Requirement Effective Date: January 25, 2026.
Senior/Key Personnel: How to Complete this Requirement: Senior/key personnel should fill out USU’s MFTRP Certification for NIH RPPR, save the file as a flattened PDF, name the file according to NIH’s required naming convention of MFTRPcert_[Name].pdf (for example, MFTRPcert_JaneDoe.pdf), and provide the file to their PI.
PIs: How to Complete this Requirement: PIs should ensure that all senior/key personnel prepare and sign their certifications prior to the RPPR submission deadline. When submitting the RPPR, PIs will upload a separate certification PDF file for each senior/key person under Section G.1 (Special Notice of Award and Funding Opportunity Announcement Reporting Requirements).
If missing from the required documentation at final review, the USU Sponsored Programs Office will contact senior/key personnel to sign a certification form to be submitted to NIH or the reporting institution.
Sponsored Programs Proposal Analyst Submitting a Proposal to NIH
Requirement: At the time of submitting a proposal, the Sponsored Programs Proposal Analyst must certify that all senior/key personnel have been made aware of and have complied with the requirement to certify that they are not a party to an MFTRP.
Requirement Effective Date: January 25, 2026.
How to Complete this Requirement: If you are the Sponsored Programs Proposal Analyst submitting the application for USU, you will certify to NIH on the SF424 R&R cover form, at the time of proposal submission, that all senior/key personnel have been made aware of and have complied with the requirement to certify that they are not a party to an MFTRP.