USDA Research Security Training Requirement

The USDA Research Security Training Requirement is the U.S. Department of Agriculture’s version of the government-wide research-security training mandate created by Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. Section 19234) and directed by NSPM-33 — the same National Security Presidential Memorandum 33 framework that produced the DOE Research Security Training Requirement and the NASA Research Security Training (GIC 26-02) requirement, and that parallels NIH’s Research Security Training (RST). This page covers what USDA’s requirement asks for and flags exactly which specifics remain unverified against a primary USDA source as of this writing.

What USDA’s requirement is reported to say

Multiple university sponsored-programs and research-compliance offices — not USDA itself, in the sources checked for this page — report that USDA introduced its research-security training requirement through Secretary’s Memorandum SM 1078-014, dated July 8, 2025, and then incorporated the requirement into USDA’s General Terms and Conditions for grants, cooperative agreements, and similar financial-assistance instruments, with an effective date reported as December 31, 2025. Under that reported framework, named ‘covered individuals’ on a USDA-funded application must complete an approved research-security training course, and completion is certified to USDA as part of the award’s standard terms and conditions rather than through a separate compliance filing.

What CASRAI could not independently confirm: at the time of writing, direct fetches of USDA’s own memorandum PDF and General Terms and Conditions document did not complete, so the SM 1078-014 document number, the July 8, 2025 memorandum date, and the December 31, 2025 effective date are reported here as secondary-source information, corroborated across more than one institutional research-compliance page, but not verified against USDA’s own published text. At least one secondary source separately described USDA training requirements as becoming effective October 10, 2025 — a date that does not obviously reconcile with the December 31, 2025 General Terms and Conditions effective date, which is itself a reason to confirm current wording directly against USDA’s own memorandum and General Terms and Conditions before treating any date here, including this one, as a firm compliance deadline.

Who is reported to count as a ‘covered individual’

Consistent with how ‘covered individual’ is defined under the comparable DOE and NASA requirements, secondary sources describe USDA’s covered-individual population as including the Principal Investigator, co-Principal Investigators, and other senior or key personnel named on a USDA-funded application or award — the same population that CHIPS Act Section 10634 and NSPM-33 target for research-security training and disclosure obligations across federal research-funding agencies generally. Institutions should confirm the precise covered-individual definition against USDA’s own General Terms and Conditions text, since agencies implementing the same NSPM-33 mandate have not defined the covered population identically (compare the DOE and NASA pages linked above).

Reported completion deadline and recertification

Secondary sources describe two distinct timing triggers under USDA’s requirement: training completed within 12 months prior to submitting an application, and, separately, training completed within 60 days of a project member’s appointment to an already-active award, with annual recertification thereafter. This two-track structure (pre-application plus post-appointment) is broadly consistent with how other NSPM-33 implementing agencies have approached newly added personnel, but the specific day-count and recertification cadence reported for USDA should likewise be checked against USDA’s own text rather than relied on from this summary alone.

How this fits the broader NSPM-33 landscape

USDA’s requirement sits alongside a growing set of individual federal agency implementations of the same underlying policy: NSPM-33 directed agencies to standardize research-security requirements, and CHIPS Act Section 10634 gave that direction statutory force for training specifically. DOE implemented its version through Policy Flash PF 2025-04 / FAL 2025-02 (see the DOE Research Security Training Requirement page), NASA implemented its version through Grant Information Circular GIC 26-02 (see the NASA Research Security Training (GIC 26-02) page), and NSF has layered comparable training-certification requirements into its own NSPM-33-driven policy notices. Because each agency has issued its own notice, memorandum, or circular on its own timeline, an institution that receives funding from more than one of these agencies should expect to track separate effective dates, covered-individual definitions, and certification mechanics per agency rather than assuming one training completion satisfies every funder’s requirement automatically — though in practice a single qualifying course (for example, a course built to the SECURE Center’s consolidated research-security training model referenced in DOE’s guidance) may be accepted by more than one agency.

Related terms

• NSPM-33
• DOE Research Security Training Requirement
• NASA Research Security Training (GIC 26-02)
• NIH Research Security Training (RST)
• CHIPS and Science Act