As of May 1 2025, DOE requires all covered individuals to:

• Complete Research Security Training within 12 months prior to proposal submission.
• Have an ORCID iD and include it in Current & Pending support disclosures

DOE Covered Individual Definition

An individual who (a) contributes in a substantive, meaningful way to the development or execution of the scope of work of a project proposed for funding by DOE, and (b) is designated as a covered individual by DOE.

DOE designates as covered individuals 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.

DOE departmental elements will often expand this list of designated roles, as specified in the applicable Notice of Funding Opportunity (NOFO) and/or terms and conditions of the Federal financial assistance award. Status as a consultant, graduate (master’s or PhD) student, or postdoctoral associate does not automatically disqualify a person from being designated as a "covered individual" if they meet the definition in (a) above.

See: 

DOE Malign Foreign Talent Recruitment Program Certification

The  in Current and Pending Support documentation and does not allow participation in Malign Foreign Talent Recruitment Programs.

 within their Current and Pending Support.

Effective October 10, 2025, NSF requires all covered individuals to:

• Complete Research Security Training within 12 months prior to proposal submission.

NSF Covered individual Definition

Principal investigators (PIs) and other senior/key person seeking or receiving Federal research and development funding (i.e., extramural funding) and researchers at Federal agency laboratories and facilities (i.e., intramural researchers, whether or not federally employed), including Government-owned, contractor-operated laboratories and facilities.

See 

NSF Research Security Training Requirements

Effective October 10, 2025, . This training must be completed by all covered individuals (key personnel) prior to proposal submission to NSF.

NSF Malign Foreign Talent Recruitment Program Certification

Effective May 20, 2024, covered individuals must individually certify that they are not a party to a malign foreign talent recruitment program. The SciENcv Biographical Sketch and Current and Pending (Other) Support documents require each individual to certify that the information provided is accurate, current, and complete, and that they are not a party to a malign foreign talent recruitment program. Effective June 7, 2025, all PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov that they are not party to a MFTRP.

Effective October 1, 2025, NIH requires all senior/key personnel:

•  Complete disclosure training at Just-In-Time

Effective May 25, 2026, NIH requires all senior/key personnel:

•  Complete research security training prior to proposal submission

NIH Covered Individual Definition

A “covered individual" is defined as all senior key personnel (i.e., individuals who contribute to the scientific development or execution of a project in a substantive, measurable way).

NIH Research Trainings

Disclosure Training: Effective October 1, 2025, NIH requires senior/key personnel complete disclosure training at Just-In-Time.

You may choose either the CITI Research Security Training 1-hour or 4-hour course which will satisfy both the NIH Research Security Training requirement and the Disclosure training requirement.

Research Security Training: Effective May 25, 2026, NIH requires senior/key personnel complete research security training prior to proposal submission.

 This training must be completed by all covered individuals (senior/key personnel) prior to proposal submission to NIH.

In accordance with the Chips and Science Act, each covered individual must certify that they have completed the training within 12 months of the date of application submission. This certification will be collected at the time of application submission, through the Biographical Sketch in SciENcv.

NIH Malign Foreign Talent Recruitment Programs

Principal Investigators and Key Personnel on NIH awards are currently prohibited from MFTRP participation. For more information, please review the 

Effective August 5, 2026, NASA requires all covered individuals (senior/key personnel):

• Complete research security training prior to proposal submission and certify completion on the biographical sketch and current and pending (other) support forms.
• For any covered individual joining a NASA-funded project after an award, certify completion of research security training on the biographical sketch and current and pending (other) support forms.

NASA Covered Individual Definition

A “covered individual” is defined as any Principal Investigator (PI) (regardless of level of effort), any CoPI (regardless of level of effort), and only Co-Investigators (Co-I) proposing to spend ten percent or more of their time in any given year on a NASA-funded award.

NASA Research Trainings

Research Security Training: Effective August 5, 2026, NASA requires senior/key personnel complete research security training prior to proposal submission. Any senior/key personnel joining a project after an award shall complete research security training prior to joining the project.

 announces a research security training requirement for Senior/key personnel on NASA applications. This training must be completed by all covered individuals (senior/key personnel) prior to proposal submission.

In accordance with the Chips and Science Act, each covered individual must certify that they have completed the training within 12 months of the date of application submission. This certification will be collected at the time of application submission, through the NASA Biographical Sketch and Current and Pending support forms.

NASA Malign Foreign Talent Recruitment Programs

Principal Investigators and Key Personnel on NASA awards are currently prohibited from MFTRP participation.

Effective July 8, 2025, USDA requires all covered individuals including senior/key personnel:

• Certify that research security training has been completed not more than one year prior to the date of proposal application and certify annually for the duration of the award
• Certify they are not party to a malign foreign talent recruitment program and recertify annually for the duration of the award

USDA Covered individual Definition

Per the , an "Individual" means covered individual, senior/key person, or any other individual employed by the recipient to work on the research arrangement, including an individual who (a) contributes in a substantive, meaningful way to the scientific development or execution of a research project proposed to be carried out as part of a research arrangement with USDA; and (b) is designated as a covered individual by USDA. Consistent with National Security Presidential Memorandum 33 (NSPM-33), this means principal investigators (PIs) and other senior or key personnel seeking or receiving USDA research and development funding (i.e., extramural funding) and researchers at USDA laboratories and facilities (i.e., intramural researchers, whether or not federally employed), including Government-owned, contractor-operated laboratories and facilities.

USDA Research Security Training Requirements

Per the USDA’s July 8, 2025 :

As a term and condition of entering into an arrangement with USDA related to research and development (R&D or science and technology (S&T), applicants must certify that research security training has been completed not more than one year prior to the date of application and must recertify annually for the duration of the award.

USDA Malign Foreign Talent Recruitment Program Certification

Certify they are not party to a malign foreign talent recruitment program and must recertify annually for the duration of the award. Individuals are not eligible to work on USDA-supported projects if they have participated in a Malign Foreign Talent Recruitment Program within the last ten years.

See