Are You Covered? Understanding the USDA’s New Research Security Mandates

For years, research security requirements have focused primarily on senior and key personnel listed on federal grants. That approach is now changing quickly.

Recent updates signal a clear shift toward expanding research security expectations to everyone involved in a research project, not just principal investigators or senior staff. One of the most significant changes appears in the updated guidance, which emphasizes that covered individuals must report all sources of current and pending support, including funding for students and postdoctoral researchers that comes from entities outside their home institution. This marks a notable expansion of accountability across the full research workforce.

This broader approach is reinforced by new Research Security Training (RST) mandates from the U.S. Department of Agriculture (USDA). Under these requirements, every individual employed by the award recipient who works on the project must complete research security training within 12 months of starting work and recertify annually. The covered individuals will include undergraduate, graduate, and postdoctoral students, as well as visiting scholars working on USDA-funded projects. This is a major departure from the requirements of many other federal agencies, which typically limit mandatory training to senior or key personnel only.

Taken together, these changes reflect a growing federal trend: research security is no longer confined to leadership roles. Instead, agencies are increasingly recognizing that risks can emerge at any level of a research project. This approach aligns with recent Department of Defense guidance and the Administration’s broader push to view research security as a shared responsibility.

For institutions, this means policies, training programs, and compliance processes must evolve. For researchers at every career stage, it’s a reminder that research security expectations now extend well beyond the PI.

The message is clear: research security is no longer just a senior responsibility. It’s an institutional one.

Source: Important Notice No. 149: Updates to NSF Research Security Policies