The purpose of this webpage is to provide the Brown community information on new and emerging research security policies and guidance. Here, you will find regulatory background information, links to federal directives related to research security, and research-security related resources available to the Brown community. As new federally mandated research security requirements are implemented, additional information will be added to this website and will be disseminated to the research community. If you have questions, please contact the Office of Research Integrity at [email protected].

Jump to: What is Research Security | NSPM-33 | Federal Directives | Brown Resources | Implementation at Brown

Introduction

Open national and international scientific and scholarly research and collaborations are critical to furthering Brown’s mission to serve the community, the nation and the world by discovering, communicating and preserving knowledge. In support of this mission, Brown continues to be firmly committed to fostering international collaborations. 

Over the last several years, the federal government and federal funding agencies have started to take an interest in research security.  Many new federal policies and directives focus on mitigating security risks that may arise in research, and particularly research involving  international collaborations. To meet the requirements of the new policies and directives, Brown and its researchers must maintain practices dedicated to securing sensitive research data and intellectual property, disclosing potential conflicts of interest and conflicts of commitment, and adhering to export control regulations.  

What is Research Security?

The term “Research Security” broadly includes requirements that aim to safeguard the research enterprise against misappropriation of research to the detriment of U.S. national and economic security. 

Regulatory Background  

NSPM-33 - Directive to Federal Agencies

In January 2021, National Security Presidential Memorandum 33 (NSPM-33) was published and directed federal agencies (e.g., National Science Foundation, National Institutes of Health, Department of Energy) to embark on a coordinated effort to improve research security and streamline operations to ease administrative burden on recipients of federal research funding. 

NSPM-33 identified five key areas that federal agencies are required to address: 

  1. Disclosure Requirements and Standardization 
  2. Digital Persistent Identifiers 
  3. Consequences for Violation of Disclosure Requirements 
  4. Information Sharing 
  5. Research Security Programs

Since then, the federal government has issued guidance to agencies regarding implementation of NSPM-33 directives.  Many federal agencies have started the implementation process and have issued policies and instructions effectuating research security requirements.

Additional federal directives, policies and regulations

In January 2022, one year after NSPM-33 was published, the Joint Committee on the Research Environment (JCORE) published Guidance for implementing NSPM-33 for U.S. government-supported research and development. In this report, JCORE provided guidance primarily intended to aid federal research agencies in harmonizing processes.  

In August 2022, CHIPS and Science Act was signed.  It focuses on advancing U.S. global leadership in the technologies of the future, including semiconductors and advanced computing, and in part, prohibits federally funded researchers from participating in Malign Foreign Talent Programs. The National Science Foundation is leading the effort to implement the Act. 

In March 2023, the Office of Science and Technology Policy (OSTP) published the Draft Research Security Programs Standard Requirement and requested comments by June 3, 2023. OSTP is now reviewing the comments and finalizing the Research Security Programs Standard Requirement. Once finalized, Brown will start implementing the requirements. 

In August 2023, the National Science Foundation (NSF) published a request for comments on the draft Common Disclosure Forms that all federal funding agencies will likely use. Use of common forms is expected to simplify disclosure of relevant activities for senior/key personnel on grant applications. NSF reviewed comments and is implementing the new forms in the 2024 PAPPG, effective May 20, 2024.

Other federal agency policies and directives related to research security

National Science Foundation - 2024 Proposal and Award Policies and Procedures Guide(Effective May 20, 2024)
Department of Energy - Conflict of Interest Policy (2021)
Department of Defense - Policy for Risk-Based Security Reviews of Fundamental Research (2023)
National Institutes of Health - Policy for Subaward Written Agreements (2023)

Brown Resources for Faculty and Researchers

Brown’s implementation of the new requirements

Brown has created a working group with representation from a number of different offices, including University Compliance Office, the Office of the General Counsel, Global Travel Operations, Risk & Resilience, the Office of Information Security, the Office of the Vice President for Research, the Office of the Provost, the Office of Global Partnerships, and the Office of the Dean of Faculty, to develop policies, procedure and infrastructure to effectuate new research security requirements. If you have any questions or would like to ger involved with the working group, please email the Office of Research Integrity at [email protected].