NSPM-33

National Security Presidential Memorandum 33 (“NSPM-33”) was a directive from President Trump that was subsequently endorsed by President Biden. NSPM-33 requires all federal research funding agencies to strengthen and standardize disclosure requirements for federally funded awards. NSPM-33 also mandates the establishment of research security programs at research institutions receiving federal funds. NSPM-33 will also require oversight and enforcement activity in the form of administrative actions as well as civil or criminal penalties.

NSPM-33 aims to protect U.S-funded scientific research from undue foreign influence, including exploitation of the open university research environment and intellectual property theft. While Texas A&M values and encourages international collaborations that promote openness in research and scholarship, Texas A&M must comply with US laws and agency regulations that govern how we manage and report international engagements. This includes NSPM-33, which requires all federal research funding agencies to strengthen and standardize disclosure requirements and mandates the establishment of research security programs at research institutions that receive federal funds. Understanding the regulatory environment, the risks, and importance of transparency is an individual responsibility as well as an organizational commitment.

Outlined commitments to the following areas:

• Engaging regularly with the research community and other stakeholders to share information
• Standardizing disclosure information to assess potential conflicts of interest and conflicts of commitment
• Coordinating agency policy development for researcher digital persistent identifiers
• Developing research security program standards

NSPM-33 requires a certification from research organizations awarded more than $50 million per year in total Federal research funding, that they have implemented a research security program that includes the four elements:

• Cybersecurity
• Foreign travel security training
• Research security training
• Export control training

Research security training is mandated for individuals involved with federally funded research by U.S. federal regulations such as the CHIPS and Science Act and NSPM-33.

• Within 12 months PRIOR to an application submission, covered individuals must complete research security training.
• Covered individuals must certify that they have completed the training via the Current and Pending Support Disclosure certification.
• Institutions must certify that all covered individuals who are listed on the application have completed the research security training.

Covered individuals are any principal investigators (“PI”), project director (“PD”), co-principal investigator (“Co-PI”), co-project director (“Co-PD”), and any individual regardless of title that is functionally performing as a PI, PD, Co-PI, Co-PD, or project manager, as well as anyone designated by the DOE.

At this time, some federal agencies like DOE and NSF are requiring covered individuals to complete research security training prior to a proposal submission. We expect other federal agencies to follow.

The options for meeting the Research Security Training requirement are:

• Complete all four of the following modules: 
  • TrainTraq course 2114744 NSF Module 1 - Introduction to Research Security
  • TrainTraq course 2114745 NSF Module 2 - The Importance of Disclosure
  • TrainTraq course 2114746 NSF Module 3 - Manage and Mitigate Risk
  • TrainTraq course 2114747 NSF Module 4 - The Value of International Collaboration

OR

• Complete TrainTraq course 2114875: Research Security Training (Combined)

The frequency by which the training must be taken may be annually due to the language in the CHIPS Act stating “...within 12 months of submitting a research and development application to a federal agency…”

Other Resources:

• TAMU Division of Research International Collaborations web page
• NSPM-33
• TAMU Research Security and Export Controls web page