Mandatory Research Security Training Requirement – Effective November 1, 2025

Dear Faculty,

We are writing to inform you of a new mandatory Research Security (RS) training requirement that was implemented at Emory on November 1, 2025, in alignment with federal mandates.

Why is this training required?

This training is mandated by the CHIPS and Science Act of 2022 and NSPM-33, and is increasingly being included in the terms and conditions of subawards from other institutions. Federal agencies such as NIH and NSF have begun enforcing these requirements, with additional mandates taking effect in the coming months.

What does the training cover?

The RS training addresses key areas including:

• Foreign travel and foreign components
• Export controls and cybersecurity
• Disclosure requirements and persistent identifiers
• Insider threat awareness
• Foreign talent recruitment programs
• Data sharing and other support

How will training be completed?

Emory has developed a comprehensive training module hosted in the Brainier Learning Management System, which consolidates all federal requirements into a single approximately 45-minute session. This module is regularly updated to reflect evolving federal guidance.

Completion of the training will be tracked in the Investigator Portal, currently under development, which will provide a dashboard for compliance reporting accessible to researchers, ADRs, administrative staff, OSP, and RCRA. A pilot of this dashboard will launch next month with a select group of researchers.

Key Deadlines:

• October 1, 2025: NIH requires Other Support training for key personnel.
• October 10, 2025: NSF requires key personnel on proposals to have completed RS training within the prior 12 months.
• January 25, 2026: NIH requires certification that key personnel are not affiliated with a malign foreign talent recruitment program (MFTRP).

We encourage all faculty engaged in federally funded research to complete the training as soon as possible to ensure compliance and avoid delays in proposal submissions or funding.

If you have questions or need assistance accessing the training, please don’t hesitate to reach out.

Contact for questions: 

researchcompliance@emory.edu

researchsecurity@emory.edu

Emory University Research Security Training Rollout Plan

Objective

To implement a comprehensive and compliant research security training program for Emory researchers, ensuring alignment with federal agency requirements including NIH, NSF, DOE, and DoD.

Federal Compliance Requirements Overview

NIH Requirements (Effective January 25, 2026 for applications)*

• Covered Institutions must certify they have a research security program with:

• • Cybersecurity
  • Foreign travel security
  • Research security training
  • Export control training
• Covered Individuals (senior/key personnel) must:
  • Complete research security training within 12 months prior to application submission.
  • Certify completion at proposal and annual reporting stages

NSF Requirements (Effective October 10, 2025)

• All senior/key personnel must:
  • Complete research security training within 12 months prior to proposal submission.
  • Certify completion on their Current & Pending Support

General Federal Requirements

• Training must cover:
  • Foreign influence
  • Disclosure responsibilities
  • Cybersecurity practices
  • Conflict of interest and commitment
  • Proper use of federal funds

• *NIH Other Support requirements are effective Oct 1 onwards and training will be verified at JIT. Requirement is also being enforced as part of terms & conditions in subs from other institutions of higher education. 

Training Content and Delivery

Training Module

Required research security training can be found in Brainier. Log into Brainier via PeopleSoft Self Service Learning Management prior to clicking on this link to access the training. Alternatively, you can log into Brainier via PeopleSoft Self Service Learning Management and search for training modules by subject matter to access the training modules.

Implementation Timeline

Roles and Responsibilities

• Office of Research Compliance & Regulatory Affairs: Program oversight, policy alignment, reporting
• School Research Deans: Monitor completion, assist with certification
• Researchers: Complete training and submit certification

Tracking and Documentation

• Integrate training records into Emory’s NSPM33 Dashboard.
• OSP & RAS teams have visibility into dashboard for training completion checks
• Maintain audit-ready logs for federal review.

Support and Communication

• Launch awareness campaign via email, intranet, and faculty meetings.
• Provide FAQs, help desk support, and office hours.