International Engagement

Federal-wide Research Security Efforts

National Security Presidential Memorandum-33 (NSPM-33) was developed by federal agencies through the National Science and Technology Council’s (NSTC’s) Research Security Subcommittee and issued by the White House on January 14, 2021. The purpose was to strengthen protections of U.S. Government-supported Research and Development (R&D) against foreign government interference and exploitation. A focus was ensuring that participants in U.S. federal R&D fully disclose information that can reveal potential conflicts of interest and commitment. This led to the November 2023 publication of common disclosure forms (biosketch and current and pending/other support) intended for federal-wide use.  

NSPM-33 also called for the establishment of comprehensive research security programs at institutions receiving >$50 million annually in federal R&D funding. Research security programs are to include four crucial elements: 

  • Cybersecurity
  • Foreign travel security
  • Research security training
  • Export control training, as appropriate 

These elements were further defined in NSPM-33 Implementation Guidance developed by the NSTC’s Research Security Subcommittee and issued by the White House in January 2022.  On July 9, 2024 the Office of Science and Technology Policy released final Guidelines for Research Security Programs at Covered Institutions.  An overview and rough timeline for implementation are included below. Institutions are awaiting implementation requirements from research funding agencies and upon publication will have approximately 12-18 months to implement them.

text: Overview of the Final Guidelines for Research Security Programs<br />
 Cybersecurity • Implement a cybersecurity program one year after publication of the final NIST cybersecurity resource (IR 8481: Cybersecurity for Research) Foreign Travel Security Implement federal foreign travel security training to covered individuals (CI) within 1 year of availability and at least every 6 yrs. • Organizational record of Cl international travel when agency determines securit y risks warrant travel reporting for an R&D award Research Security Training •Implement research security training; certify Cl completion • Option A: NSF training modules Option B: Non-federal training that covers: (1) Improper transfer of USG-supported R&D; (2) importance of International research & talent Export Control (EC) Training • Provide EC training to Cl working with controlled technology • Option A: Govt. training (BIS, DDTC) Option B: Non-fed training with U.S. EC and compliance requirements & processes for reviewing foreign sponsors, collaborators, and partnerships
text: Approximate Timeline for Implementation<br />
July 9, 2024 OSTP releases Guidelines for Research Security Programs at Covered Institutions to heads of federal agencies. January 8, 2025 Within 6 months of the date of OSTP Guidelines, federal agencies shall submit to OSTP & OMB plans for updating their policies to address the Guidelines in their research security program standards. January 2025-July 2025 Federal agencies shall implement their updated policies no later than 6 months after finalized plans are submitted to OSTP & OMB. January 2025-July 2026 Covered institutions shall have no more than 18 months after the effective date of agency plans to implement their requirements.<br />
Courtesy of the Council on Governmental Relations

Research Security Training

The National Science Foundation, National Institutes of Health, Department of Defense, and Department of Energy funded four cooperative agreements to develop training in best practices to optimize research security. The four modules center on the following four critical questions:

  • Why is research security an important issue?
  • What is a disclosure policy and how will it be used?
  • What actions can federally funded research recipients take to manage and mitigate risk? 
  • Is international collaboration encouraged? 

Training modules have been released and are available for institutions to adapt and use.

U-M, in collaboration with the Ohio State University, Stanford University, and Duke University, has developed a condensed and consolidated one-hour version of the four federal training modules that other academic institutions or organizations can download for their use.  This training includes two editable html-based files that can be modified to supply institution-specific contact information and links to resources.

How to replace the placeholder resources and contact packages within the SCORM package with institution-specific contact information and links to resources.

Transcript for the consolidated version is provided by CITI Program.  CITI Program subscribing institutions wishing to track completion of the consolidated course may do so via CITI Program.

For U-M faculty, staff, students, and UM-affiliated subcontractors working on grants or contracts where the sponsor currently requires research security training as a term of your award, U-M offers the condensed Research Security Training course version in My LINC.  Questions can be directed to [email protected].