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Does the education requirement apply to new Key Personnel involved in human subjects research whose names are added on non-competing Progress Reports?

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Does the education requirement apply to new Key Personnel involved in human subjects research whose names are added on non-competing Progress Reports?

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Yes. NIH expects that all Key Personnel will receive the required education before beginning research involving human subjects. If Key Personnel are added to an award in a non-competing year, documentation that they have received the required education should be included in the non-competing Progress Report. • Do individuals identified as Key Personnel who are not involved in the design and conduct of the human subjects portion of an award need to comply with the education requirement? No. Investigators who are identified as Key Personnel, but are not involved in the design and conduct of human subjects research do not need to comply with this requirement. • Does the education requirement apply to Key Personnel involved in human subjects research supported by an NIH award if they will not be compensated by the award? Yes. The education requirement applies to all individuals involved in the design and conduct of human subjects research supported by an NIH award whether or not they recei

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