OSTP Issues August Update on Research Security
NSPM-33 IMPLEMENTATION STATUS
On Aug. 31, 2022, the White House Office of Science and Technology Policy (OSTP) published an update on its blog regarding the implementation of National Security Presidential Memorandum 33 (NSPM-33), which it announced in January. OSTP’s update highlighted four key topics:
- Draft standardized disclosure requirements: National Science and Technology Council’s (NSTC’s) Subcommittee on Research Security (SRS) released draft standardized data fields and instructions for pre- and post-award disclosures relating to biographical sketch and current and pending (other) support documents among researchers applying for federal funding, which will be piloted by the National Science Foundation (NSF).
- NSTC outreach: SRS engaged with the U.S. research community, hosting engagement hours in the spring of 2022, which were attended by a diverse mix of nearly 40 organizations. OSTP noted that further outreach by NSTC will continue.
- DPI planning: NSTC worked to develop policies related to NSPM-33’s requirement for researchers to be registered with a digital persistent identifier (DPI), which included recent working groups led by OSTP and the Department of Energy (DOE) having discussions and designing a thoughtful, comprehensive approach to federal wide implementation.
- Research security programs: SRS has continued to clarify and specify the research security program requirement contained in NSPM (for research organizations that receive less than $50 million in federal science and engineering funding for more than two consecutive years). In addition, the CHIPS and Science Act of 2022 set forth additional guidance regarding the security training portion of research security programs.
Actions You Can Take Now
As public comment on the draft disclosure forms is underway, and new details related to the implementation of NSPM-33 continue to emerge, institutions can mobilize to consider:
- People and resource needs: Assess the impact of these new requirements for research administration and compliance teams. Determine what additional resources may be required in order to manage compliance, or if existing resources need to be redeployed.
- Policies, procedures, technology, and data impacts: Review how these new requirements might challenge current processes and workflows.
- Disclosure requirements related to in-kind support, externally funded investigators (visiting scholars, postdoctoral fellows, and graduate students), and noninstitutional funding received by investigators may require access to data that is often not readily available to grant administrators. Compliance will involve a broader approach and stakeholders (e.g., contracting offices, human resources, graduate student affairs).
- Consider ways in which information can be shared across functional areas to meet new and emerging research compliance requirements.
- Organizational models: Delegate the institutional responsibility to implement, oversee, and monitor the programs that enable compliance with these regulations. Establish how your institution can best activate organizational readiness to comply with requirements that are pending finalization (e.g., disclosure requirements) or still in flight (e.g., research security programs and DPI use).
- Communication: Activate training and education resources at your institution in order to facilitate regular communication about new disclosure requirements with faculty and research personnel.
- Mission, strategy, and values: Engage thoughtfully with your leaders and the broader research community at your institution to determine how to balance academic freedom, diversity and inclusion, and compliance with federal guidance.
How Huron Can Help
Huron’s team of research compliance experts has supported institutions with proactive assessments of foreign interference and research security and compliance programs, responding to both federal sponsor and enforcement agency investigations and delivering training for faculty, departments, and central office staff. Our team has deep expertise supporting research institutions by working to update and implement policies and procedures in response to regulatory updates.
Additionally, Huron Research Suite provides a long-term software solution to streamline collecting and managing various disclosures required by NSPM-33.
If you have concerns or questions regarding your institution’s practices or readiness to implement these updates, contact one of our leaders today.