“Senior/key personnel” (SKP) is the NIH term for everyone named on a grant application whose role is measurable and committed — not just the Program Director/Principal Investigator (PD/PI), but co-investigators and anyone else who contributes substantively to the scientific development or execution of the project. Being designated SKP triggers a specific bundle of NIH training and certification obligations that is separate from, and easy to confuse with, the ORCID iD requirement for senior/key personnel — that requirement is about identity disclosure (linking a unique, verified iD to each SKP’s eRA Commons profile), not training. This guide covers the actual training and certification obligations: responsible conduct of research (RCR) training, NIH’s newer research security training (RST) requirement, financial conflict-of-interest (FCOI) training, and mentoring plan requirements for trainees on career-development and training mechanisms.
Who counts as senior/key personnel
NIH defines senior/key personnel as individuals who contribute in a substantive, measurable way to the scientific development or execution of a project, whether or not they request salary support in the budget. The PD/PI is always senior/key personnel; co-investigators, and sometimes other named scientists, typically are as well. Postdoctoral associates and graduate students are ordinarily NOT senior/key personnel unless their role rises to that level — they are usually classified as “other significant contributors” or listed as trainees under the relevant mechanism instead. This distinction matters because several of the requirements below (RCR training and mentoring plans, in particular) actually attach to trainee status on specific award mechanisms, not to senior/key personnel status itself — the two overlapping-but-different populations are a common source of institutional confusion, so check which population a given requirement actually covers before assuming it applies.
Responsible conduct of research (RCR) training
NIH’s RCR instruction requirement is not a blanket rule for every senior/key person on every award. It applies to individuals supported by specific NIH research-training and career-development mechanisms — Kirschstein-NRSA institutional training grants (T32, TL1, T90/R90), individual fellowships (F30/F31/F32), career development (K-series) awards, research education awards (R25), and international research training programs (D43/D71) — where NIH refers to the covered population as “trainees, fellows, participants, and scholars.” Program directors and mentors on these mechanisms are also generally expected to have current RCR training and to participate in instruction, even though their own funding line isn’t RCR-conditioned in the same way.
The governing notices are NOT-OD-10-019 and NOT-OD-22-055. The substantive requirements NIH has been consistent about:
- A minimum of eight contact hours of instruction.
- Face-to-face, discussion-based engagement is required as a substantial component — NIH has explicitly stated that a plan relying entirely on self-paced online coursework is not acceptable except in narrow, well-justified circumstances. A fully-online course (including CITI Program’s RCR series) can supplement an NIH-compliant plan but does not satisfy the requirement on its own.
- Instruction at least once during each career stage (e.g., separately at the predoctoral, postdoctoral, and faculty levels), not a single training completed once and carried forward indefinitely.
- Coverage of core topics: research misconduct and policies for handling it, data management and sharing, publication practices and authorship, peer review, mentor/mentee responsibilities, collaborative research, human subjects and animal welfare (where relevant), and conflicts of interest.
See the Responsible Conduct of Research (RCR) training dictionary entry for the operational definition, and Science Mentorship: NIH Mentoring Plans, K-Awards, and Training Grants for how RCR instruction plans fit into the broader training-grant application package.
Research security training (RST) — the newer, broader-reaching requirement
Distinct from RCR, NIH has been rolling out a research security training requirement that applies specifically to senior/key personnel named on NIH applications, implementing obligations under Section 10634 of the CHIPS and Science Act of 2022 and aligning with the government-wide research-security push already reflected in NSPM-33 and comparable requirements NSF, DOE, USDA, and NASA have each stood up for their own funded populations. Per the NIH Guide notice governing this requirement (most recently NOT-OD-26-017, “Research Security Training Requirements for NIH”), the core mechanics are:
- Who: every individual listed as senior/key personnel on an NIH application.
- Content: topics consistent with the government-wide research-security training model — cybersecurity awareness, foreign interference and foreign talent recruitment program risks, proper disclosure of foreign support and affiliations, and conflict-of-commitment/conflict-of-interest obligations.
- Validity window: completion is valid for 12 months, so training has to be current as of submission, not merely completed at some point in the past.
- Certification: each individual certifies completion (reported secondary sources describe this being captured via the SciENcv biographical sketch), and the Authorized Organization Representative (AOR) additionally certifies on the application’s signed face page that all covered personnel have met the requirement.
- Effective date: applications with due dates on or after May 25, 2026 must comply.
This RST requirement is separate from, and layered on top of, an earlier and narrower NIH training obligation tied to Other Support disclosure (NOT-OD-25-133), effective October 1, 2025, which addresses how to correctly complete Other Support and biosketch disclosures rather than research-security awareness generally — see Other support (NIH format), Biosketch (NIH-style), and the related NIH Other Support Template guide for that requirement specifically. NIH’s research-security notices have been revised more than once in a short window (a pattern consistent with the comparable NSF, DOE, and USDA notices — see Research Security), so treat the effective date and exact notice number above as current at time of writing and verify the live text at grants.nih.gov before relying on it for a specific submission.
For the disclosure side of foreign-support obligations that RST reinforces rather than replaces, see Undue foreign influence and the CASRAI guides on the Malign Foreign Talent Recruitment Program (MFTRP) and US-China Research Collaboration: Research Security and Compliance Concerns.
Financial conflict-of-interest (FCOI) training
Separately from both of the above, NIH’s financial conflict-of-interest regulation — 42 CFR Part 50, Subpart F — requires every “Investigator” (NIH’s term, defined as the PD/PI and anyone else responsible for the design, conduct, or reporting of NIH-funded research, a population that substantially overlaps with senior/key personnel) to complete FCOI training before engaging in the research and at least once every four years afterward. Training must also be repeated sooner if the institution revises its FCOI policy in a way that affects the investigator’s obligations, if the investigator is new to the institution, or if the institution finds the investigator out of compliance with the policy or a management plan. This is an institutional compliance obligation administered through the institution’s own FCOI policy (commonly delivered via CITI Program’s COI module), not a certification made directly to NIH on the application itself.
Mentoring plans for trainees
Mentoring plan requirements attach to specific mechanisms, not to senior/key personnel status generally. K-series career development awards and most training/fellowship mechanisms (T32, individual F awards, some R25s) require a mentoring plan describing the candidate’s proposed research training, career development activities, and the mentor’s (or co-mentoring team’s) qualifications and plan for oversight. This is a distinct application component from RCR training, though the two are closely related in practice — a training grant’s RCR instruction plan and its mentoring plan are typically developed and reviewed together. See Science Mentorship: NIH Mentoring Plans, K-Awards, and Training Grants for the full requirements, what reviewers look for, and how mentoring plans differ across mechanisms.
Compliance checklist by role
- PD/PI or co-investigator on a standard research award (e.g., R01): FCOI training (42 CFR 50 Subpart F, every 4 years) and, from May 25, 2026 onward, current research security training certified at submission. RCR training is not required unless the award itself is a training/career-development mechanism.
- Trainee, fellow, or scholar on a T/F/K/R25/D43 mechanism: RCR training (8 contact hours, substantial in-person component, per career stage) plus a mentoring plan documented in the application. Senior/key personnel-level requirements (research security, FCOI) apply on top of this if the individual is also senior/key personnel on the award, which K-awardees typically are.
- Mentor/program director on a training grant: current RCR training expected alongside participation in instruction, plus the standard senior/key personnel obligations (FCOI, research security).
Frequently asked questions
Does every senior/key person on an NIH grant need RCR training?
No. RCR training is tied to specific NIH training and career-development mechanisms (T, F, K, R25, D43/D71) and the “trainees, fellows, participants, and scholars” they support, not to senior/key personnel status on every award type. A senior/key person on a standard R01 with no training-mechanism component is not automatically subject to the RCR requirement, though FCOI and research security training still apply.
Is NIH’s research security training the same as the Other Support disclosure training?
No — they are separate, both real NIH requirements. Other Support disclosure training (NOT-OD-25-133, effective October 1, 2025) addresses how to correctly complete Other Support and biosketch disclosures. Research security training (most recently under NOT-OD-26-017, effective for applications due on or after May 25, 2026) is broader, covering cybersecurity, foreign interference, and conflict-of-commitment awareness, and is certified separately.
How is completion of NIH research security training documented?
Reported guidance describes individual certification captured through the SciENcv biographical sketch, with the institution’s Authorized Organization Representative additionally certifying completion for all covered senior/key personnel on the application’s signed face page. Confirm the current documentation mechanism against the live NIH Guide notice before a submission, since this area has been revised more than once.
Does CITI Program’s online RCR course satisfy NIH’s RCR requirement by itself?
No. NIH requires a substantial face-to-face or live-discussion component in addition to a minimum of eight contact hours; a plan built entirely on self-paced online coursework is not acceptable except in narrow, well-justified circumstances. An online course like CITI’s RCR series can supplement an NIH-compliant plan but cannot serve as the entire plan.
How often must FCOI training be renewed?
At least every four years under 42 CFR 50.604, and sooner if the institution’s FCOI policy changes in a way that affects the investigator, the investigator is new to the institution, or the institution finds them noncompliant with the policy or an existing management plan.
