Senior/Key Personnel Certification
ORPA-L: Fri, 02 Oct 2026
Dear Researchers and Research Administrators
Nearly all federal research sponsors now require that both the University and each individual who contributes in a substantive, meaningful way to a federal research project certify to various research security requirements. Additional background on these requirements is provided below.
To comply with these requirements, the University now requires all individuals identified as Senior/Key personnel on a proposal to a federal sponsor to complete the “Certify” activity in the IORA grants management system. A guide to complete that certification is linked here.
Background
The University and each “Covered Individual” must certify to various requirements at the time of proposal submission.
A Covered Individual is someone “who (A)contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and (B) is designated as a covered individual by the Federal research agency concerned” (CHIPS and Science Act of 2022). This definition closely aligns to the traditional definition of Senior/Key personnel. Notably, part B of this definition permits sponsors to name other specific individuals or categories of individuals as Covered Individuals.
Examples of the requirements that must be certified to by the University or Covered Individuals at the time of proposal include the following:
In accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232), the Authorized Organizational Representative (AOR) must certify that all individuals identified as Senior/Key personnel or Covered Individuals have been made aware of and have complied with their responsibility under that section to certify that the individual is not a party to a malign foreign talent recruitment program.((NSF Special Notice; NIH NOT-OD-26-018;,DOE)
Each individual identified as Senior/Key personnel or Covered Individual must certify that they are not a party to a malign foreign talent recruitment program. (NSF Special Notice; NIH NOT-OD-26-018;,DOE)
The AOR must certify that each Senior/Key personnel or Covered Individual who is employed by the institution and listed on the application has completed Research Security Training within 12 months prior to proposal submission. (NSF Special Notice; NIH NOT-OD-26-017;,DOE)
Each individual identified as Senior/Key personnel or Covered Individual must certify that they have completed Research Security Training within 12 months prior to proposal submission. (NSF Special Notice; NIH NOT-OD-26-017;,DOE)
Thank you,
Anthony Beckman, Associate VP for Research AdministrationJoe Doyle, Research Security Officer
Please contact your ORPA Research Administrator with any questions.