As of October 10, 2025, the National Science Foundation (NSF) requires all individuals listed as senior/key personnel on NSF proposals to complete research security training within 12 months prior to proposal submission.   This training, mandated by the CHIPS and SCIENCE Act of 2022, ensures proper disclosure of current and pending (C&P) support and addresses risks of foreign interference in U.S. research.  See NSF Research Security July 10, 2025, for more information. 

Rutgers Research and Sponsored Programs (RSP) must certify that all senior/key personnel have met this requirement.  If this requirement is not met by all senior/key personnel, the proposal will NOT be submitted to NSF to ensure compliance with the federal requirement. 

• Ensure all individuals involved in the proposal are indicated in Section 2.0 of the Research Administration and Proposal Submission System (RAPSS) Funding Proposal (FP) module.  When completing the questions in this section, be sure to indicate if these individuals are Senior/Key personnel.
• The PI/co-PI must ask each Senior/Key person to complete the training.  Training must be completed within 12 months prior to submission of the proposal to the sponsor.  We recommend completing the training early to avoid issues with your submission.
• Research Security Training is available through Rutgers CITI.  You are only required to take the combined-1 hour version of the training, although you are welcome to take the expanded 4-hour version.  If you have already taken the Research Security Training course in CITI (either the combined 1-hour version or the longer expanded version) within 12 months of the submission date, you do not need to retake it for the submission.
• If you are planning to include subrecipients in your submission, they also need to indicate that their PI / CoPI and their senior/key personnel included in their budget have taken the necessary Research Security Training within 12 months of the proposal submission date.  The Subrecipient Commitment Form has been updated to include this requirement.

To register for CITI Training, please visit Rutgers Research Security CITI License.  It is recommended that you retain a record of completing this course by choosing “View-Print-Share Record” to obtain a certificate. 

If you have issues accessing CITI, please contact the Rutgers CITI administrator at ofr_citi@research.rutgers.edu.

If you have questions, please contact your RSP grant specialist. 

Per Section 2.5.1 “Just-in-Time Procedures” of the NIH Grants Policy Statement, all Principal Investigators (PIs), Co-PIs, and Senior/Key Personnel must disclose all research activities and affiliations (active and pending) in their Other Support forms.

Effective October 1, 2025, and pursuant to NOT-OD-25-133, NIH requires all PIs, Co-PIs, and Senior/Key Personnel to complete NIH-specific training on Other Support disclosure requirements on an annual basis. Your RSP Grant Specialist (GS) will verify that the PI, co-PIs (if any), and all senior/key personnel indicated in the proposal have taken the required training prior to the submission of the Just-in-Time (JIT) documentation or the Research Performance Progress Reports (RPPR). This requirement also applies to subrecipients.

If this requirement is not met by PI, Co-PIs (if any), Senior/Key Personnel, and subrecipients (if any) identified, the RSP GS will NOT proceed with the respective submission (JIT or RPPR).

What you need to do (Summary of NIH Other Support Requirements for JITs and RPPRS):

• Ensure that all individuals involved in the proposal (for JITs), or active awards (for RPPRs), are indicated in Section 2.0 of the Research Administration and Proposal Submission System (RAPSS) Funding Proposal (FP) module record, or RAPSS Award (AWD) module record, respectively. When completing the questions in this section, be sure to indicate the roles of these individuals in the project, especially if they are Co-PIs or Senior/Key personnel.
• It is the responsibility of the PI/Co-PI/Department Administrator to ensure that all individuals identified as Rutgers PI, Co-PIs, and Senior / Key Personnel complete the Research Security Training course in CITI (either the combined 1-hour version or the longer expanded version) within 12 months of the  JIT or RPPR (annual, interim, or final) submission date. Research Security Training is available through Rutgers CITI.
• It is the responsibility of the PI/Co-PI/Department Administrator to ensure that all subrecipient(s)’ PIs, Co-PIs, and Senior / Key Personnel confirm that they meet this training requirement as well before the JIT or RPPR submission deadline. Please provide the NIH Other Support Disclosure Certification Statement form to each of the subrecipient(s) for completion.  The form must be signed by the Subrecipient’s AOR and submitted to your RSP GS as part of the JIT, or RPPR, documentation prior to submission date.

To register for CITI Training, please visit Rutgers Research Security CITI License.  It is recommended that you retain a record of completing this course by choosing “View-Print-Share Record” to obtain a certificate. 

For additional guidance regarding how to complete your Other Support, please visit Rutgers – NIH Other Support.

If you have issues accessing CITI, please contact the Rutgers CITI administrator at ofr_citi@research.rutgers.edu.

If you have questions, please contact your RSP grant specialist.

On Monday, September 29, 2025, NIH issued NOT-OD-25-161, rescinding notice NOT-OD-25-154, which required the completion and certification of research security training for NIH proposals and RPPR submissions. 

Investigators and Sr./Key personnel are not required to complete specific Research Security Training prior to submission of NIH proposals or RPPRs until further guidance is provided from NIH in the coming months.

As of September 11, 2025, individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP) are NOT eligible to serve as a PI, Co-PI or Senior/Key Person on an active NIH grant or cooperative agreement.

As of January 25, 2026, and with the implementation of the Common Forms for Biographical Sketch and Other Support, via SciENcv, PIs, Co-PIs, and all senior/key personnel will be certifying that they are not a current party of an MFTRP.  This requirement extends to the subrecipients.  The Rutgers Authorized Organization Representative (AOR), i.e., the RSP GS, must certify that all individuals identified in the application PI, Co-PI, or senior/key personnel have been made aware of and have complied with their responsibilities to make the appropriate certification on their Common Forms.

On Monday, September 29, 2025, NIH issued NOT-OD-25-161, rescinding notice NOT-OD-25-154, which required the provision of an individual document signed by each PI, Co-PI, or key personnel indicating if they are, or they are not, participating in an MFTRP, as part of an RPPR submission.  Such documentation is not required until further guidance is provided by NIH in the coming months.