Agency Update: Changes to Research Security Requirements

In early 2026, most federal agencies updated their certification for biographical sketches and current and pending support documents, requiring that investigators: 

1. Fulfill Research Security Training requirement within the past 12 months, and 
2. Certify that they are not party to a malign foreign talent recruitment program. 

Many investigators have questions about the new certification, including who needs the updated training, how to complete the training to be compliant with the new requirements, and what it means to be involved in a foreign talent recruitment program. Here you will find information addressing these common questions and steps to take so that you are prepared to certify documents for your next application. 

Updated Research Security Training 

Who? 

Anyone certifying their biographical documents - typically key/senior personnel - must have completed research security training (RST) compliant with the 2022 Chips and Science Act and NSPM-33 within the past 12 months. The UC Davis Office of Research Ethics, Compliance, and Safety office provides more information for investigators who need to complete RST on the Responsible Conduct of Research (RCR) website. 

What? 

To be compliant with the most up-to-date research security training, UC Davis recommends completing the CITI RCR course which satisfies the federal requirements for NSF and NIH. 

Additionally, every 2 years all key personnel must complete the UC Ethics and Compliance Briefing for Researchers.

All covered individuals must complete the research security training within the specified timeframe outlined by each sponsoring agency. The trainings mentioned above are compliant for NIH and NSF and we anticipate that other agencies will adopt the same training as the default requirement.

Training is also offered at least twice per year in the Office of Research RCR Program (last offered 6/22/2206). 

How? 

For the CITI RCR Course, UC Davis affiliates can log into the CITI RCR system using campus SSO login. 

• Go to: www.citiprogram.org 
• Choose Log In through My Organization (use “Davis” in search) and log in through your Keberos login (more information on logging in can be found here) 
• Scroll down to Add a Course 
• Check the box that says “I need to enroll in Research Security Training” 
• Choose “Research Security Training (Combined Course)”, which is a condensed yet compliant version of the Basic Course. Investigators should expect the course to take 60-90 minutes to complete.  

For the UC Ethics and Compliance Briefing

• Navigate to https://uc.sumtotal.host, select UC Davis and login
• Once logged in, enter Ethics Briefing in the Search Learning tab in the top navigation panel 
• Select “UC Ethics Compliance Briefing for Researchers” to launch the online module

What is a foreign talent recruitment program? 

A Malign Foreign Talent Recruitment Program is a foreign government-sponsored program that offers compensation or incentives to researchers in ways that may conflict with U.S. research integrity or federal funding obligations. Most researchers are not involved in such programs, but it is a good idea to understand what they are so that you can avoid such involvement. 

There are no lists of such programs, however, the UCOP Ethics, Compliance and Audit Services provides a definition of and a list of characteristics of a MFTRP. Individuals participating in any foreign programs are advised to review the definition and characteristics to see if the program meets the listed criteria.