Do Key Personnel need to document this requirement for each different grant or contract award?
Yes, required education applies to all key personnel involved in each different project that includes human subjects. This includes all individuals involved in the design and conduct of the study, whether or not they receive compensation from the award. This documentation should be provided to the NIH on a project-by-project basis for multi-component awards. This specific requirement will be subsumed under the Office of Research Integrity (ORI) requirement for education on Responsible Conduct of Research. The ORI requirement is an assurance process that will operate at the institutional level and take the place of this requirement for person-specific information on each award.
