Body
University Standard
Title
University of North Carolina at Chapel Hill Standard on Research Security Training
Introduction
The University of North Carolina at Chapel Hill conducts federally funded research that is subject to federal research security requirements. These requirements are established under National Security Presidential Memorandum-33 (NSPM-33), codified in the CHIPS and Science Act of 2022, and implemented through guidance issued by the Office of Science and Technology Policy and sponsoring federal agencies, including the National Institutes of Health.
Federal sponsors require institutions to provide Research Security Training addressing disclosure obligations, foreign affiliations and activities, and other risks associated with sponsored research including cybersecurity, export controls, and foreign travel security.
The University’s Research Security Training Program provides institution-specific Research Security Training to support compliance with these requirements.
Purpose
This standard implements the University of North Carolina at Chapel Hill Science and Security Policy by establishing requirements for Research Security Training for individuals participating in federally funded research.
Scope
This standard applies to individuals who participate in, or propose to participate in, federally funded research activities conducted under the auspices of the University of North Carolina at Chapel Hill and who are required to complete Research Security Training based on role, activities, or sponsor requirements.
Individuals within this scope must know and follow this standard. For purposes of this standard, individuals within this scope are referred to as Covered Individuals.
Standard
1. Roles Subject to Training
Research Security Training is required for Covered Individuals when they are listed in one of the following roles in the Research Administration Management System & eSubmission (RAMSeS) for a federally funded project:
- Lead Principal Investigator (Lead PI)
- Principal Investigator (PI)
- Investigator
- Postdoctoral Research Associate
- Clinical Research Coordinator
- Fellow
- Fellow (individual NIH Fellowship)
- Other Key Participant (faculty only)
- Faculty Advisor (when the Lead PI is a Postdoctoral Research Associate)
- New Lead PI (award only)
- Other roles as identified by the Institutional Science and Security Officer or federal sponsors
2. Timing of Training
Unless a federal funding agency requires a different schedule, Covered Individuals must complete Research Security Training before submitting proposals to a federal funding agency. Training remains valid for 365 days from the date of completion and must be renewed each year.
Sponsored Programs will not initiate a new award until all Covered Individuals have completed the required training. The Institutional Science and Security Officer, or designee, may document and approve an exception to this requirement.
3. Training Frequency
Covered Individuals subject to this standard must complete Research Security Training annually.
4. New Covered Individuals
Newly appointed Covered Individuals must complete required Research Security Training prior to beginning work on a federally funded project, consistent with the timing requirements in this standard.
5. External Collaborators
When Research Security Training is required for Covered Individuals who are external collaborators participating in federally funded research, the training requirement may be satisfied through completion of equivalent Research Security Training offered by the collaborator’s home institution, provided the training meets applicable federal requirements.
When an equivalent training is not available, Covered Individuals must complete the National Science Foundation (NSF) Secure Center’s Consolidated Training Module (CTM) before participating in the research.
6. Administration and Oversight
The Science and Security Program, overseen by the Institutional Science and Security Officer, is responsible for establishing and maintaining Research Security Training requirements, monitoring training completion, and updating training requirements in response to changes in federal guidance, sponsor expectations, or institutional risk.
Carolina Talent serves as the University-designated system of record for Research Security Training completion.
7. Compliance
Failure by Covered Individuals to complete required Research Security Training may result in administrative action consistent with University policies and procedures, including delays in project initiation or modification and other actions necessary to ensure compliance with applicable requirements.
Related Requirements
External Regulations
University Policies, Standards, and Procedures
Contact Information
Primary Contact
Name: Brian Collier
Title: Institutional Science and Security Officer
Unit: Science and Security Program, Office of the Vice Chancellor for Research
Email: bcollier@email.unc.edu