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Research Security Training Requirement Effective Oct. 1: Overview, Impacts and How To Be Prepared
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U-M requires research security training to ensure compliance with federal regulations and institutional policies. The requirement applies to all sponsors for external funding.
Overview of new requirement
Starting Oct. 1, all U-M investigators listed on an eRPM PAF, AWD or MOD record requiring approval from the Office of Research and Sponsored Projects (ORSP) must have completed the PEERRS Research Security Training (RST) module within the past 12 months. This requirement also applies to any other senior/key personnel or “covered individuals,” as defined by the sponsor in the solicitation.
Take Action! Notify your investigators and covered individuals now to avoid delays with PAF submission and AWD/MOD processing. After Oct. 1, PAFs won't be approved and AWDs/MODs will go on compliance hold unless the RST training is complete.
Note: The PEERRS DoJ Bulk Data Regulations Training module (implemented on Aug. 25, 2025) is separate from the RST module. For PAF approval, only the RST module is required. However, both modules must be completed to avoid compliance holds on AWD and MOD records.
How this will impact PAFs, AWDs & MODs
Impact on PAF
- PAFs will be returned as “Incomplete” (per Deadline Policy FAQ #6) if all investigators listed on the PAF have not completed the RST module by the time the PAF arrives at ORSP. This applies to all PAFs regardless of how question 1.2 is answered (proposal, contract or subsequent PAF).
- If a PAF arrives at ORSP on Sept. 30 or earlier, the RST module requirement will not be enforced.
- PAFs that arrive at ORSP on Oct. 1 or after will not be approved unless this requirement is met by all U-M investigators and covered individuals.
- To assist with this requirement, a red warning message will appear in the center of the main PAF workspace from the time the investigator(s) is added to the PAF record if they have not completed the RST module:
- Important note: The warning message functionality will be live in the eRPM system starting Sept. 22. ORSP will not be enforcing the requirement until the Oct. 1 requirement is in effect; however, we encourage investigators to take the training so they are ahead of their compliance requirements.
- The RST module must be completed within 12 months prior to PAF approval by ORSP. U-M is applying this requirement to all sponsors and investigators.
- For solicitations that define “covered individuals,” they must each also complete the RST module within 12 months prior to PAF approval by ORSP.
- Check the PAF “Contacts” tab in the “PEERRS Info” section to see which investigators need to complete the RST module.
Impact on AWD & MOD
- AWD and MOD records will go on compliance hold if the RST module is not completed by all investigators.
- From Sept. 22-30, when eRPM will be updated but the new requirement has not taken effect, ORSP will coordinate with ITS to manually release compliance holds for the RST module once per day.
- eRPM will automatically release PEERRS compliance holds when the required modules are completed Oct. 1 and after.
Impact on Subcontracts issued by U-M
- Effective Oct. 1, for NIH, NSF and DOE, all subcontractors to U-M must complete the RST for their investigators and “covered individuals” and reflect this in their completed subrecipient form for proposal submission.
- On U-M’s Subrecipient Statement of Collaborative Intent the certification box is:
What to do
If any of your team members are investigators on PAF records or are listed on active AWD and MOD records, advise them to complete the 1-hour PEERRS RST module as soon as possible to avoid delays. The training must be renewed annually for all U-M investigators and covered individuals.
To check an investigator’s certification status, visit the PEERRS Certifications Lookup. Certifications can also be checked by school/college and primary appointing department.
The eRPM system refreshes hourly to update training completion information from My LINC.
If investigators have previously completed the NSF Research Security Training outside of My LINC, submit the training certificate to the PEERRS team ([email protected]) to have the training reflected in our system.
For more information
- Did you know? The NIH Other Support Training and Policy Requirement NOT-OD-25-133 (applicable to NIH proposals submitted after Oct. 1) is covered under U-M’s Research Security Training module and SOP 200.03.
- For more information on the training, visit the Research Security Training Course Details webpage.
- Information on PEERRS requirements is available on the PEERRS Training Requirements webpage.
- Additional information on “covered individuals” and fulfilling the requirement for non-UM subcontract personnel is available in the July 2025 RAP article.
- Questions regarding the training requirement can be directed to [email protected].