Resources for organizations defining their approach to research security

As the research security landscape continues to evolve, research administration and compliance leaders will need to quickly determine their readiness and ability to adapt to changing federal guidance. Huron will continue to stay close to these topics and publish resources that analyze and interpret new guidance as it becomes available, such as:

The release of model proposal disclosure forms.
The implementation of uniform agency proposal applications.
Further details on NSPM-33’s requirement for research security programs.
Additional regulatory, legislative, or enforcement updates as they continue to emerge.

Latest Developments

On March 7, 2023, the White House Office of Science and Technology Policy (OSTP) released its first Request for Information (RFI) for research security programs required by NSPM-33. The RFI builds on proposed research security program requirements originally introduced in NSPM-33 and its implementation guidance. The comment period for the RFI ends on June 5, 2023. Key clarifications and additions from existing NSPM-33 implementation guidance include:

Clarifying that the requirement for a research security program applies to institutions receiving $50M in “federal science and engineering support for the previous two consecutive fiscal years,” inclusive of sub-awards to the institution.

The requirement applies to discrete universities. It does not apply in aggregate to all universities that are part of a university network (e.g., a public university system).
The RFI suggests measuring federal science and engineering support based on data available at USA Spending and/or NSF Federal Science and Engineering Support to Universities, Colleges, and Nonprofit Institutions.

Confirming that foreign travel will require institutional authorization for Principal Investigators and senior/key personnel engaged in federally funded research traveling for organizational business, teaching, conference attendance, research purposes, or who receive offers of sponsored travel for research or professional purposes, and that all such travel must be maintained in an organizational record.
Expanding on requirements for research security training (note that NSF awarded funding to several institutions to develop research security training modules).
Confirming that cybersecurity requirements will align to and be driven by the National Institute of Standards and Technology, including focusing on access controls, user authentication, and detecting and preventing malicious code.
Describing training requirements for export controls, including “that the ‘fundamental research’ exception has explicit limitations,” providing an example of how export controls may impact applied energy technology.

The RFI provides several working definitions of key terms, including conflict of commitment, foreign government-sponsored talent recruitment programs, and research security.

Institutions will have one year to comply with finalized research security program requirements. They will be required to post a publicly available update on their progress within 120 days of finalized requirements.

^NEWMaybe Forgotten But Not Gone – From the China Initiative, to NSPM-33, to CHIPS, and Beyond: Understanding and Responding to the U.S. Government’s Shifting but Continued Focus on Safeguarding Research Webinar
Published May 3, 2023
Huron’s research security experts, Amanda Ferguson and Greg Smith, with legal experts Christine Savage and Mark McPherson from Choate Hall & Stewart, LLP, discuss the current status of the National Security Presidential Memorandum 33 (NSPM-33) implementation and provide an update on how the industry is adapting to this rapidly changing research security environment.

This webinar provides a brief overview of the evolution in research security concepts over the past few years, updates attendees on ongoing and recently completed enforcement actions, analyzes the implications of the NSPM-33 implementation roll-out (from the uniform disclosure forms pilot to the recently released draft Research Security Program requirements), describes how the 2022 CHIPS and Science Act implementation may continue to impact research security matters, and discusses some best practices that institutions have adopted that reflect different approaches to research security compliance.

^NEWNational Science Foundation (NSF) Proposal & Award Policies & Procedures Guide (23-1)
Published Oct. 26, 2022
The newest NSF includes revisions to the biosketch and current and pending support templates to include individual principal investigator certifications attesting to the accuracy and completion of information. NSF has also announced that program officers will begin requesting updated current and pending support information prior to making funding recommendations.

OSTP Issues August Update on Research Security
Published Sep. 30, 2022
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 Issues Foreign Interference and Research Security Implementation Guidance
Published Feb. 1, 2022
On Jan. 4, 2022, the White House Office of Science and Technology Policy (OSTP) published a blog post announcing OSTP’s release of guidance to federal agencies toward implementing National Security Presidential Memorandum 33 (NSPM-33), which set forth national security strategy and principles for strengthening the protections of U.S.-funded research and development against foreign interference and exploitation.

International Collaboration With Foreign Influence Risk
Published Oct. 1, 2021
Learn more about higher education compliance requirements and how institutions can improve their administrative structures, featuring guidance from experts at Huron, Duke University, and the FBI. The piece outlines the steps that some institutions are taking to further strengthen their risk management and compliance programs and mitigate foreign influence risk.

How Cyber Hygiene Promotes Information and Data Security for Research Institutions in a New Era for Remote Work
Published June 29, 2021
As more institutional research moves to the remote environment, some institutions are rethinking the need to provide dedicated physical space for research faculty, staff, and administrators who don’t require labs or special equipment on campus. But cost savings and conveniences realized in this new model will not come without an abundance of complicated considerations for the deployment of dedicated virtual facilities that are required for personnel who operate off campus.

Seeing Around the Corner: Using Intellectual Property Data to Proactively Monitor Foreign Influence Risk
Published April 27, 2021
By now, universities and colleges are very aware of the increased federal and state scrutiny around relationships between U.S.-funded researchers and foreign entities. Many institutions have taken or are considering taking steps to strengthen controls for conflicts of interest and commitment disclosures, information security and export controls, and the foreign gifts and contracts reporting process.

Section 117: Where Foreign Influence and Gift Management Often Collide
Published March 15, 2021
This article discusses the Department of Education’s increased efforts to monitor colleges’ and universities’ compliance with Section 117 of the Higher Education Act of 1965. Due to concerns surrounding potential foreign interference in U.S. research efforts, Congress has proposed legislation to reduce the reporting threshold from $250,000 to $50,000.

Not Just an IT Problem: Considerations for Data Security Compliance in Research Organizations
Published Jan. 26, 2021
During this webinar, Huron research compliance expert Greg Smith and data security experts Merritt Neale discuss key data security compliance areas and best practices for organizations.

Foreign Influence Challenges and the Trajectory of a Continued Regulatory Focus
Published Jan. 19, 2021
Research compliance leader Anne Pifer and Michael Vernick of Hogan Lovells discuss foreign influence in U.S.-government-sponsored research during this webinar. The pair explores the regulations driving foreign influence inquiries and enforcement activity, provides thoughts on what may be coming in 2021 from a regulatory and enforcement perspective, and delivers suggestions to help you manage risk and, when needed, respond to foreign influence investigations.

Fostering International Collaboration While Managing Undue Foreign Influence in Academic Research
Published Oct. 22, 2020
As global collaboration increases and instances of questionable influence by foreign entities over federally funded research continue to surface, institutions are being called to enhance compliance programs to mitigate this evolving risk. This intensified spotlight on compliance with shifting regulatory demands has created a complex and high-stakes environment in which failure to adhere to federal mandates may lead to formal inquiries and civil or even criminal charges.

Navigating Foreign Influence in Research Compliance
Published July 31, 2019
Compliance program planning is an iterative exercise; academic research leaders need to regularly reevaluate planned compliance activities to keep pace with noncompliance incidents, revised regulations, or emerging focus areas. One growing focus area for regulators and institutions is foreign influence in research.

Foreign Influence Client Alert
Published July 25, 2019
This alert provides clarification and guidance around what the National Institutes of Health (NIH) considers Other Support and Foreign Components. Huron will continue to follow developments in this area and across the foreign influence landscape, providing updates and added perspective as we see how this notice resonates and is put into practice in the research community.

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