NSPM-33 Training and Certifications

The annual cybersecurity training already in place at all campuses meets the requirements for NSPM-33. Completion is required of all employees during the annual training window. The training is found in My Talent on KU-Lawrence affiliated campuses and SABA on KU Medical Center campuses. 

The National Science Foundation (NSF) developed four training modules that together satisfy the Research Security Training requirement of NSPM-33. Each module is approximately one hour in length. This training is hosted on the CITI platform for both KU Lawrence affiliated campuses as well as KU Medical Center affiliated campuses. Alternatively, depending on your funding agency's requirements, you may satisfy the Research Security Training requirement by completing the one-hour Research Security Training (Combined) course on the CITI platform. Researchers should check with KUCR or RA grant specialists to ensure this course satisfies the specific funding agency's requirements. Completion of this course is required annually for all Principal Investigators (PIs) and Senior/Key Personnel (SKPs). 

Export control training covers a broad range of topics including international shipping, deemed exports, and international travel. This training is hosted on the CITI platform and the initial "Export Compliance (EC) Stage 1" course is approximately one hour in length. After completing the initial training, employees may complete the "Export Compliance (EC) Stage 2-Refresher" course to meet the annual requirement. Every sixth year, employees will repeat the above cycle of Basic and Refresher courses. Completion of this course is required annually for all Principal Investigators (PIs) and Senior/Key Personnel (SKPs). 

Export control also includes training on complying with requirements and processes for reviewing foreign sponsors, collaborators, and partnerships. This training hosted on the CITI platform is titled "International Collaborations" course and is approximately 25 minutes in length. Completion of this course is required annually for all Principal Investigators (PIs) and Senior/Key Personnel (SKPs).

Per the Office of Science and Technology Policy memorandum issued July 9, 2024, Foreign Travel Security training will be developed by a consortium of federal funding agencies like NIH, NSF, DOE, and DOD. That training has not yet been published. To meet the requirement, the University offers the "International Travel" module on the CITI platform. The training is less than 20 minutes in length. Completion of this course is required annually for all Principal Investigators (PIs) and Senior/Key Personnel (SKPs).

Certain funding agencies, specifically the Department of Defense, have begun to incorporate CUI requirements into their solicitations and grant contracts. KUCR and the RA can help identify those grants and solicitations that have this requirement. Further, GRS can develop a Technology Control Plan (TCP) to ensure your environment remains compliant throughout the duration of your grant. CUI environments have associated costs and should be budgeted for at the time of application. Researchers will need to complete the CITI based "CUI Training for Researchers" if their grant has this requirement. 

Office of Science and Technology Policy (OSTP) as well as KU Policy requires all researchers to certify that they are not participating in a Malign Foreign Talent Program. The University has developed a certification form that defines a Malign Foreign Talent Program and allows the research to attest to non-participation. The Non-Participation in Malign Foreign Talent Program certification should be completed and provided to grant specialists upon proposal submission or request. 

NASA has specific certifications for recipients of NASA grants. From NASA:

"In accordance with restrictions in Appropriation Acts, NASA is prohibited from funding any work that involves the bilateral participation, collaboration, or coordination with China or any Chinese-owned company or entity, whether funded or performed under a no exchange of funds arrangement. Proposals involving bilateral participation, collaboration, or coordination in any way with China or any Chinese-owned company, whether funded or performed under a no exchange of funds arrangement, may be ineligible for award." 

The University has developed a certification form that defines the requirement and allows the researcher to attest they currently and will continue to meet this requirement throughout the duration of the grant. The NASA certification should be completed and provided to grant specialists upon proposal submission or request. 

Per agency and KU Policy, Principal Investigators (PIs) and Senior/Key Personnel (SKPs) shall create a profile of record on the Open Researcher and Contributor Identification (ORCiD) platform and verify their ORCiD with the University via an approved mechanism. The libraries on both campuses can provide education and best practices as it pertains to the setup of an ORCiD profile. Please use the following links:

KU Lawrence affiliated campuses
KU Medical Center affiliated campuses