National Security Presidential Memorandum 33
In January 2021, the U.S. government issued the National Security Presidential Memorandum 33 (NSPM-33), a national security policy for U.S. Government-supported R&D. NSPM-33 mandates research institutions receiving more than $50 million per year in federal funds establish research security training programs to protect against foreign government interference while maintaining an open environment to foster research discoveries and innovation that benefit the US and the world.
UB’s Regulatory Support and Sponsored Project Services teams will support faculty in adhering to the new guidelines
and ensure compliance with these new regulations.
It includes general guidance that agencies should apply across their implementation efforts, followed by more detailed guidance in five key areas addressed in NSPM-33:
Disclosure Requirements and Standardization
This requires federal agencies to provide clarity regarding disclosure requirements (e.g., who discloses what, relevant limitations and exclusions), disclosure process (e.g., updates, corrections, certification, and provision of supporting documentation), and expected degree of cross-agency uniformity.
Impact on UB:
Agencies will request information about researchers and their employment, including potential outside activities. This drives the new requirements around COI disclosures and foreign talent recruitment programs
Digital Persistent Identifiers
Federal research agencies shall incorporate digital persistent identifiers (DPIs) also known as Persistent Identifiers (PIDs).
Impact on UB:
Funding agencies may require PIs to have DPIs moving forward.
Consequences for Violation of Disclosure Requirements
Federal agencies will define processes for determining level of violations, and consequences for violation of disclosure requirements and engagement in other activities that threaten research security and integrity.
Impact on UB:
For violation of disclosure requirements, penalties range from individual PIs being barred from review panels, suspension of funding, criminal or civil charges.
Information Sharing
NSPM-33 defines what circumstances federal agencies can share information regarding violations and potential violations and provide assurance regarding how such sharing will be limited to respect privacy and other legal and reasonable protections.
Impact on UB:
This rule may require more communication with institutions when deciding on public notifications.
Research Security Programs
UB will be required to establish a research security program that includes the four elements:
- Cybersecurity
- Foreign travel security (NDI Travel Registry)
- Research security training
- Export control training
Quick Links
If you have questions about NSPM-33 or would like to share your thoughts,
please complete this form.