NASA Research Security Requirements

Per Grant Information Circular (GIC) 26-02, issued February 5, 2026 and effective August 5, 2026, NASA implemented a research security training requirement. 

"Covered individuals" named on a NASA grant or cooperative agreement proposal must certify that they have taken required research security training within 12 months prior to a proposal submission or at the time they are added to an award that has already been issued. 

Definition of Covered Individuals

For purposes of NASA's requirement, covered individuals are defined as: 

• any Principal Investigator, regardless of level of effort
• any Co-Principal Investigator, regardless of level of effort
• any Co-Investigators proposing to spend 10% or more of their time in any given year on a NASA-funded award

Notably, NASA funding organizations may designate additional personnel categories as covered individuals on a project-by-project basis. These designations will be explicitly stated in all Notices of Funding Opportunities. 

To complete this training requirement, log in to LMS and take the Research Security at the University of California training. 

Per the NASA Grant and Cooperative Agreement Manual (GCAM), Principal investigators, co-principal investigators, and senior/key personnel are prohibited from participating in a Malign Foreign Talent Recruitment Program. 

UCSF Policy

Reminder: MFTRPs often create unmanageable conflicts of commitment. Applying to or participating in a Foreign Talent Recruitment Program (FTRP) or a MFTRP is classified as a Category I Outside Activity and requires prior institutional review and approval. All UCSF researchers must disclose any involvement in a FTRP or MFTRP as part of their annual Conflict of Interest Disclosure in Research Gateway. 

For details on the distinction between FTRPs and MFTRPs, please visit the Foreign Talent Recruitment Programs page on the Office of Ethics and Compliance website. Additional training associated with this and other research security issues can be found in the UC Learning Center (search for “Research Security at the University of California”).