»Federal Training Requirements
Commitment to Compliance with Federal Mandates & Training Requirements
Chapman University is committed to ensuring that all research activities supported by federal funding are conducted with integrity and in compliance with applicable federal regulations, grant terms and mandated training requirements. By reinforcing these responsibilities, the university helps safeguard its eligibility for federal support while promoting integrity and accountability in research.
Through this guidance and other relevant policies, the university establishes institutional expectations for Principal Investigators (PIs), research staff, students, and other senior/key personnel, who are responsible for ensuring that their projects are conducted in a manner consistent with federal regulations and mandates. Failure to comply with federal requirements or award terms and conditions may result in suspension, delay, termination, or loss of eligibility for federal funding for either the individual or the university.
Each federal agency has unique, specific training requirements which Principal Investigators (PIs) should familiarize themselves with to ensure they and their research teams comply. These federal training requirements apply to PIs, co-investigators, senior/key personnel, research staff, students, and others significantly contributing to a project. Each individual must complete the necessary training as required by the sponsoring agency, and they must remain current with all relevant training throughout the duration of the project.
In addition, all researchers are expected to review and follow the research integrity policies listed on the Office of Research website. The university will provide guidance and periodic reminders to PIs and research personnel as needed; however, ultimate responsibility for compliance rests with the PIs and their research teams.
Recent Federal Training Mandates
Research Security Training Required for NSF Proposal Submissions
Effective October 10, 2025, the National Science Foundation (NSF) requires that all senior/key personnel identified on an application must complete Research Security Training within 12 months prior to proposal submission to NSF. This training requirement applies whether Chapman University is applying directly to the NSF or is anticipating a subaward through a pass-thru institution/prime recipient.
Principal Investigators (PIs) preparing an NSF application should ensure all senior/key personnel participating in the proposed project complete the NSF condensed Research Security online training module prior to proposal submission; each individual should download and provide a copy of their certificate verifying completion to the Principal Investigator (PI). Training records are subject to audit for compliance and may be requested by NSF prior to award issuance.
PIs should ensure that any independent contractors (i.e., individuals participating in the project without an institutional affiliation) have complied with this policy and completed the required training. Any new Senior/Key Personnel added during the course of an existing NSF award must complete the NSF condensed Research Security online training module.
Policy on Other Support Disclosure for NIH Submissions
Effective October 1, 2025
Consistent with the principles of transparency, accountability and integrity in research, Chapman University requires all Senior/Key Personnel[i] on proposals to, or awards from, the National Institutes of Health (NIH) to disclose all research activities and affiliations (active and pending) in the Other Support[ii] information submitted at the Just-in-Time (JIT) stage and in Research Performance Progress Reports (RPPRs).
It is critical that Senior/Key Personnel on proposals to, or awards from, the NIH fully understand their obligation to disclose all resources made available to them in support of, and/or related to, all of their research endeavors, regardless of whether or not these resources have monetary value and regardless of whether they are based at, utilized for, or available through the applicant institution or not.
Requirement
All Senior/Key Personnel on proposals to or awards from the NIH are required to review the following information:
- NIH Grants and Funding - Other Support topic page: Other Support | Grants & Funding
- NIH Pre-award and Post-award Disclosures Related to the Biographical Sketch and Other Support: NIH Disclosures Table (PDF)
- NIH Other Support Instructions: NIH Other Support Instructions
Footnotes
[i] Senior/key personnel is defined as the Program Director/Principal Investigator
(PD/PI) and other individuals who contribute to the scientific development or execution
of a project in a substantive, measurable way, whether or not they request salaries
or compensation.
[ii] Other Support encompasses all resources, whether federal, non-federal, commercial
or institutional, that are available in direct support of an individual's research
endeavors, including but not limited to research grants, cooperative agreements, contracts,
and/or institutional awards.
[ii] Chapman University acknowledges, with appreciation, Lehigh University as the
source of some of this policy language.
Training Process
- All Senior/Key Personnel must complete the NSF condensed Research Security online training module prior to proposal submission; each individual should download and provide a copy of their certificate verifying completion to the Principal Investigator (PI). Training records are subject to audit for compliance and may be requested by NIH prior to award issuance.
- All Senior/Key Personnel on existing NIH awards must complete the NSF condensed Research Security online training module, and review of this policy, prior to submitting a Research Performance Progress Report (RPPR). PIs are responsible for confirming that all senior/key personnel have completed the required training prior to submitting the RPPR.
- PIs should ensure that any independent contractors (i.e., individuals participating in the project without an institutional affiliation) have complied with this policy and completed the required training. Subaward institutions are expected to inform and ensure their own researchers of the Other Support disclosure requirements.
- Any new Senior/Key Personnel added during the course of an existing NIH award must complete the NSF condensed Research Security online training module, including review of this policy, prior to charging salary to an NIH award.
- The NSF (consolidated) Research Security online training, including review of this NIH Other Support policy, must be renewed annually for all Senior/Key Personnel.
Research Compliance Training Matrix
| Federal Agency | Training | Summary | Role(s) Required | When | Where to Complete |
|---|---|---|---|---|---|
| All (NIH, NSF, USDA-NIFA, and others) | Responsible & Ethical Conduct in Research (RCR) | Presents standards for responsible and ethical conduct of research. Covers the practice of scientific investigation with integrity, as established by professional norms and ethical principles. | All | NSF and USDA: When awarded NIH: Before proposal submission |
CITI |
| All (NSF, NIH, DOE, USDA) | Research/Data Security | Provides researchers with clear guidelines to protect against research security threats. | All | NSF SECURE Center | |
| All (PHS, NIH, other Public health service) | Conflict of Interest | Covers the definition of significant financial interest, the requirements for disclosing and how to do so, and the management or mitigation process. | All | CITI | |
| NIH | Other Support Disclosure Training | NIH requires awardees to report all relevant activities and resources in support of the investigators research endeavors on the Other Support (OS) form to ensure transparency and to assess potential scientific, budgetary, and/or commitment overlap and the capacity of the individual to carry out the research as proposed. | Chapman Form | ||
| Export control | Familiarity with and a basic understanding of export controls, which can be complex and dynamic. | All | CITI | ||
| *If conducting animal research | Institutional Animal Care & Use Committee (IACUC) | Includes an overview of regulations, policies, and procedures, and general information related to the care and use of animals in research. | All Animal Users | CITI, LearnUpon, LAOHP, Animal Facility Training | |
| *If using human subjects | Institutional Review Board (IRB) | Covers different aspects and requirements of human subject research. | All involved with Human subjects | CITI | |
| General Guidance | Federal Research Policies | General guidance regarding federal research policies from NSF, NIH, and other federal organizations. | As Required | Chapman Website |