Research Security Training

Reason for Policy

Adelphi University is committed to fostering a vibrant, open scholarly environment that supports collaborations with global partners. To safeguard the U.S. research enterprise and comply with federal mandates under NSPM-33 (National Security Presidential Memorandum-33) and the CHIPS and Science Act of 2022, federal grantmaking agencies, including the Centers for Disease Control (CDC), National Aeronautics and Space Administration (NASA), National Science Foundation (NSF), National Institutes of Health (NIH), and Department of Energy (DOE), require mandatory research security training for senior/key personnel on federal research awards.

This Research Security Policy and Procedures (“Policy”) sets forth the roles, requirements, and responsibilities for covered individuals to ensure that Adelphi University maintains full compliance with federal research security, disclosure, and foreign engagement mandates.

Who Is Governed by this Policy

Research security training and foreign engagement disclosures are required for all “Covered Individuals.”

For the purposes of this Policy, Covered Individuals include all investigators, faculty, staff, postdoctoral fellows, graduate students, or other personnel who contribute to the scientific/scholarly design, execution, or reporting of a project proposed for or supported by a federal research agency in a substantive, measurable way, regardless of whether they receive compensation under the award.

• All “Senior/Key Personnel” identified in a proposal or active award are automatically designated as Covered Individuals.
• In certain circumstances, postdoctoral scholars, graduate students, undergraduate students, or visiting researchers may also qualify as Covered Individuals. Principal Investigators (PIs) should consult the Office of Research and Sponsored Programs (ORSP) if there is uncertainty regarding whether a team member meets this definition.

Policy

Adelphi University requires all Covered Individuals involved in federal research proposals or active awards to:

1. Familiarize themselves with the federal research security and disclosure obligations set forth in this Policy;
2. Complete mandatory Research Security Training prior to proposal submission and on a recurring basis; and
3. Timely and accurately disclose all foreign affiliations, gifts, contracts, and outside support in accordance with federal sponsor regulations and university policy.

Failure to complete mandatory research security requirements will result in the withholding of institutional proposal submission or grant account setups

Definitions

This policy does not have definitions associated with it at this time. Upon periodic policy review, this area will be evaluated to determine if additional information is needed to supplement the policy.

Procedures

Adelphi University utilizes the Collaborative Institutional Training Program (CITI Program) to deliver required research security training.

CITI Program Access Instructions

1. Navigate to the CITI Program portal and choose “Log In” or “Register” (if first-time user).
2. Select “Adelphi University” as your organizational affiliation and log in using your Adelphi credentials/email.
3. From the course selection menu, add/select the “Research Security Basic Training” course module (covering NSPM-33, Disclosures, Conflict of Commitment, and Malign Foreign Talent Recruitment Programs).
4. Complete the course modules (estimated completion time is ~60 minutes).
5. Upon completion, generate your “CITI Completion Report/Certificate”.

Timing and Frequency

• Pre-Award Requirement: Mandatory Research Security training must be completed within the 12 months preceding proposal submission for all federal grant applications (including CDC, NASA, NSF, NIH, DOE, and DOD).
• Post-Award Requirement: Senior/Key Personnel on active federal awards must renew/complete the training annually, typically aligned with the submission of annual progress reports (e.g., NIH RPPR or NSF Annual Performance Report).

Forms

This policy does not have forms associated with it at this time. Upon periodic policy review, this area will be evaluated to determine if additional information is needed to supplement the policy.

Related Information

• NSPM-33 Implementation Guidance: Federal requirements for research security programs and disclosure standardization.
• CHIPS and Science Act of 2022 (Section 10638): Federal prohibition on participation in Malign Foreign Talent Recruitment Programs (MFTRPs).
• NSF Proposal & Award Policies & Procedures Guide (PAPPG): Updates on research security and disclosure requirements
• NIH Grants Policy Statement: Requirements regarding Other Support disclosures and research security training
• Department of Defense Academic Research Security
• Adelphi University Acceptable Use of Information Technology Resources Policy

Document History

• Last Reviewed Date: October 15, 2026
• Last Revised Date: October 15, 2026
• Policy Origination Date: October 15, 2026

Who Approved This Policy

Senior Leadership Council