Research Data & Security Required Training

Covered individuals must have completed RCR/RS training within 12 months prior to application submission. For covered individuals joining a project after award, training must be completed prior to starting work and being paid on the project.

It is strongly recommended that the training be taken as soon as possible, so that proposals or awards do not have to be held awaiting training completion.

Currently, this requirement applies to new proposal submissions only. If the agency guidance changes on this point, we will update the campus community.

No, our institutional certification upon proposal submission certifies that all covered individuals have completed the training within 12 months prior of application submission. It must be complete for the proposal to be submitted or OSP will not be able to submit.

Essentially all federal funding agencies now have research security requirements in effect. As communicated on our NSPM-33 website linked above, UNL now requires all research personnel (federally funded or not) to complete the Bridge RCR/RS training.

The definition of covered individual varies depending on the federal agency. However, it generally covers the following:

An individual who (A) contributes in a substantive, meaningful way to the scientific development or execution of an R&D project proposed to be carried out with an…award from a Federal research agency; and (B) is designated as a covered individual by the Federal research agency concerned.”  Office of Science and Technology Policy (OSTP) Memo & OSTP 2024 Foreign Talent Recruitment Guidelines

These definitions are important because they stipulate who is required to complete certain compliance requirements for submission and receipt of a federal award (e.g. COI/COC disclosures and research security training). Below is listing of specific definitions by federal agencies/sponsors:

CHIPS and Science Act

(1) COVERED INDIVIDUAL.—The term ‘‘covered individual’’ means an individual who— (A) contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and (B) is designated as a covered individual by the Federal research agency concerned. Section 10638(1) of the CHIPS and Science Act

Department of Defense (DoD)

An individual at an extramural research institution who, as designated by the extramural research institution, contributes significantly to the design or execution of a research and development project that is funded, in whole or in part, by the DoD, and who is considered essential to the successful performance of the research and development project. Covered individuals include those listed as key personnel in fundamental research project proposals (e.g., the principal investigator or co-principal investigator).

Department of Energy (DOE)

Covered Individual means 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. FAL Research Security Training Requirements for all R&D Financial Assistance Awards

NASA

NASA will designate as a covered individual any PIs (regardless of level of effort), any Co-PIs (regardless of level of effort), and only Co-Is proposing to spend ten percent or more of their time in any given year on a NASA-funded award. NASA funding organizations may designate additional personnel categories as covered individuals on a project-by-project basis, and these designations will be explicitly stated in all NOFOs. NASA Grant and Cooperative Agreement Manual

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). This covered individual definition is applicable to SBIR and STTR applicants for purposes of the SBIR and STTR Foreign Disclosure Form.

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.

NSF Proposal & Award Policies & Procedures Guide (PAPPG)

USDA Covered Individual Definition

1. An individual who meets both of the following criteria:
   • a. Contributes to the scientific development or execution of research, carried out as part of this USDA award, through any of the following responsibilities:
     • i. Directing the overall scientific direction of the project;
     • ii. Designing or critically evaluating key experiments or methodologies;
     • iii. Interpreting primary research data or results;
     • iv. Serving as a primary or senior author on publications resulting from the project;
     • v. Exercising direct supervisory authority over research personnel working on the research project; or
     • vi. Generating, handling, or having direct access to primary, pre-publication research data; proprietary materials; or critical, specialized methodologies essential to the project’s execution.
2. Is a principal investigator (PI), other senior or key personnel, or a researcher (including undergraduate, graduate, and postdoctoral students) who is not a USDA employee.

Or any other individual who USDA specifically identifies in writing as a covered individual.

USDA Terms & Conditions updates June 2026

Regarding this USDA definition, particularly 1.a.vi., we offer the following to better clarify what may or may not meet this definition:

Do casual, peripheral, junior, and/or support/laborers meet the definition of a Covered Individual?

Generally, no. The work these staff are performing for the research usually will not meet both criteria above (#1 and #2). Further, the definition of primary, pre-publication research data is critical to reference when weighing this type of question. Federal guidance regarding engagement of institutions or affiliated personnel also allows staff or other research support personnel to perform services that are routine services normally completed for commercial or other services outside of the research setting.

Examples may include:

1. Animal care staff/technicians: Animal care staff or technicians may be paid from the award and involved in limited collection of research related data (e.g. collection of animal weight/feed intake). This work involves performing routine animal care protocols and/or recording standard information as part of their daily operational activities.
2. Lab technicians: These staff may be paid from the award to collect blood samples from animal or human participants. In other words, they are appropriately qualified laboratory employees who may perform routine analyses of blood samples for investigators as a commercial or core facility service.
3. Transcription: A transcriptionist or transcription company whose employees transcribes research study interviews as a commercial or core facility service.

While it appears at first glance these employees could be generating or collecting research data, this again does not normally rise to the level of generation or access to primary, pre-publication research data. USDA Covered Individuals must contribute to the scientific development or execution of the research. Thus, the examples above would not require these employees to meet sponsor compliance requirements such as completion of research security training and certifications on participation in a malign foreign talent recruitment program (MFTRP).

Yes, if they meet the agency’s definition of a covered individual. We expect mentors, trainees, and those holding the fellowships will fall under the definition. However, you will need to review the NOFO to confirm this before routing the proposal.

Any student or postdoc listed by name or filling a TBN position on the PI, Personnel and Organizations page of the application should complete training, if they also meet the definition of a Covered Individual per the sponsor definitions.

There are a couple of options for viewing this information:

1. Login to your NU Bridge Account.
   • Click on Learning
   • Your training records and information should then be displayed as RCR/RS Bridge training/refresher along with the dates of expiration and downloadable certificate as applicable.
2. Login to your NuRamp account
   • In the top right corner, click on “Hello [NAME], Your Account
   • Click on My Profile
   • Your training records and information should then be displayed as RCR/RS Bridge training/refresher along with the dates of expiration as applicable.
     
     Please note, NuRamp automatically pulls training information from Bridge into your NuRamp account. However, it does take 24 hours from training completion for the information to be pulled in and displayed in NuRamp.
     
3. Or, see the below description about information available in the connected proposal/award information in the NuRamp OSP module.  

When listing covered individuals in the OSP NuRamp application form, COI/COC disclosure completion and RCR/RS training completion information will populate for each individual listed. This is the easiest and most comprehensive/quickest way to see statuses for covered individuals. However, please see the note above about automated training display and needing 24 hours upon completion for the training information to populate. If time is short and you are not able to verify this information via the above options, we recommend you check with the individual and ask them to provide you with their Bridge training certificate or contact the RCIS Office to verify.

Additionally, since the recently released updated USDA T&Cs define Covered Individuals more broadly, not all individuals may be listed on the OSP routing form. The Office of Research & Innovation is working quickly to ensure this programming is updated so the information displays for all applicable covered individuals. In the interim, if you need information on COI/COC disclosure or training statuses, please contact the RCIS Office.

No, our training in Bridge is designed to meet federal expectations for both Responsible Conduct of Research (RCR) and Research Security (RS) training. We will not accept other trainings.

For those institutions that meet the requirements under NSPM-33, all covered individuals named in a subrecipient’s proposal must complete training. The subrecipient entity’s signed Letter of Intent (LOI), signed by their institutional official, is a reflection they will abide by sponsor requirements. UNL relies on the letter of intent from the subrecipient as confirmation they are following requirements. If the subrecipient does not have their own training or learning management resources, they cannot use UNL’s training. Rather, they should be directed to use publicly available (free) trainings (original and annual refresher as applicable) on the NSF SECURE Center website.