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Quick Reference Table of Current & Upcoming Federal Research Security Requirements

COGR|
ActiveFederal

A matrix that lists policies and requirements under the headings of: Disclosures, Agency Risk Assessment, FCOI & COC, Training, Certifications, and Research Security Program for each federal agency. Per COGR, this tool is frequently updated to reflect the release of new documentation. Updated September 30, 2025.

NSF Important Notice No. 149

NSF|
ActiveNSF

Published July 10, 2025. Includes NSF implementation of three new requirements (and three existing ones) in alignment with the CHIPS and Science Act and NSPM-33. The requirements, effective October 10, 2025, include: a. Recipient institutions must maintain supporting documentation for foreign activities reported as current and pending (other) support, b. Senior/key personnel must certify they have completed research security training (RST) within 12 months prior to proposal submission; Recipient institutions' Authorized Organizational Representative (AOR) must certify that all senior/key personnel have completed required RST and that the institution has a plan to provide appropriate training, c. AORs at institutions of higher education (IHEs) must certify that, absent a waiver granted by the NSF Director, the IHE does not maintain a contract or agreement between the institution and a Confucius Institute.

America First Memorandum for USDA Arrangements and Research Security

USDA|
ActiveUSDA

Issued July 8, 2025. This memorandum: a. Requires all USDA Mission Areas, Agencies, and Offices to: i. Within 30 days, conduct a comprehensive review of all current USDA awards/subawards with foreign persons/entities and provide justification as to why a US recipient was not selected, ii. Effective immediately, request approval (including justification) prior to issuing an award/subaward to a foreign person/entity. b. Requires applicants (i.e., covered individuals) to: i. Complete the Common Forms for Biographical Sketches and Current and Pending (Other) Support and provide updated information annually, ii. Certify they are not a participant in a malign foreign talent recruitment program (MFTRP) and recertify annually, iii. Certify that they are not contracting with or providing benefit to any foreign person/entity in a country of concern, iv. Certify that they are not party to utilizing forced labor, v. Complete an annual disclosure of contracts associated with participation in programs sponsored by foreign governments/entities, vi. Seek approval from USDA to subaward any portion of a funded arrangement, including university students, post-doctoral fellows, and visiting researchers. c. Requires Employing Entities to: i. Certify to applicants' completion of research security training, ii. Prohibit applicants who either are currently or have in the past 10 years participated in MFTRPs from working on USDA projects, iii. Provide supporting documentation for foreign activities reported as current and pending support, iv. Review any documents required under the memorandum for compliance with USDA award terms and conditions.

DoE Financial Assistance Letter (FAL): Research Security Training Requirements for all R&D Financial Assistance Awards

Department of Energy|
ActiveDOE

Issued on October 7, 2024, this document outlines DOE's implementation of research security training requirements for covered individuals on financial assistance applications and for organizations applying for an award. The requirement was effective immediately but not mandatory until May 1, 2025. The training requirement is satisfied either by completion of the four training modules created by NSF, completion of the SECURE Center CTM (as indicated per DOE post FAL), or by a custom training program that is aligned with the CHIPS and Science Act Section 10634(b). Per DOE the training must be completed within the 12 months immediately preceding the application submission, consistent with the CHIPS Act requirements, and any covered individuals added to the project must certify that they have completed the training within 30 calendar days of joining the project.

Final Guidelines for Research Security Programs at Covered Institutions

White House OSTP|
ActiveFederal

Final Research Security Program (RSP) Guidelines published on July 9, 2024, via a memorandum to the heads of federal research funding agencies. Federal agencies are directed to implement the guidelines and provide time for institutional implementation. The four required areas are: cybersecurity, foreign travel security, research security training, and export control training. Agencies are coordinating implementation under a memorandum of agreement and anticipated to issue the requirements in early 2026.

University of Michigan Condensed Federal Research Security Training

University of Michigan (with Ohio State University, Stanford University, and Duke University)|
ActiveFederal

A condensed and consolidated one-hour version of the four federal training modules developed by the University of Michigan in collaboration with Ohio State University, Stanford University, and Duke University. Other academic institutions or organizations can download for their use. The training includes two editable html-based files that can be modified to supply institution-specific contact information and links to resources. SCORM files, Storyline file, and written version of the narrative are available.

SECURE Center Condensed Training Module (CTM) 1.1

NSF SECURE Center|
ActiveFederal

An updated one-hour condensed and consolidated federal research security training module offered by the SECURE Center. NSF, NIH, DoD, DOE, and USDA have indicated that the condensed module meets their research security requirements. The SCORM files (for upload in the institution's learning management systems), Storyline file, and transcript can also be found on the website. The training includes two, four or six editable html-based files that can be modified to supply institution-specific contact information and links to resources. A preview version can be viewed on the website and a version that offers a certificate of completion is now available.

Research Program on Research Security (JASON, March 2023)

JASON Group (commissioned by NSF)|
ActiveNSF

A March 2023 report issued by JASON and commissioned by NSF. Provides definitions of Research Integrity as adherence to accepted values and principles -- objectivity, honesty, openness, accountability, fairness, and stewardship -- that guide the conduct of research. Research Security is protecting the means, know-how, and products of research until they are ready to be shared. JASON suggests research security does not vary across disciplines, but the consequences of breaches in research security and the measures taken to prevent breaches will differ. Key points include an emphasis on training researchers on risks in international collaborations, the need to encourage collaboration with international organizations that are also concerned with research security, and avoiding creating a reputation of racial profiling or using the research security programs to disadvantage anyone based on ethnicity or nationality.

Research Security Training

NSF (in collaboration with NIH, DoE, DoD, FBI)|
ActiveFederal

Research security training developed by institutions and organizations under cooperative agreements funded by NSF in collaboration with the National Institutes of Health (NIH), Department of Energy (DoE), and Department of Defense (DoD), with engagement from the Federal Bureau of Investigation (FBI). The training consists of 4 modules: 1.) What is Research Security?; 2.) Disclosure; 3.) Manage and Mitigate Risk; 4.) International Collaboration.

CHIPS and Science Act

U.S. Congress|
ActiveFederal

Signed into law in August 2022, the CHIPS and Science Act includes a number of research security provisions. Key sections address research security at DOE, NIST cybersecurity guidance, NSF Office of Research Security and Policy, research security training requirements, information sharing analysis organizations, Confucius Institute restrictions, foreign financial support reporting, and foreign talent recruitment program requirements.

CHIPS Act Sec. 10337: Responsible Conduct in Research Training

CHIPS and Science Act|
ActiveNSF

Expands the requirement for RCR training to include faculty and other senior personnel on [NSF] awards and expands the scope of such training to include mentoring training and training to raise awareness of research security risks as well as Federal export control, disclosure, and reporting requirements.

National Security Presidential Memorandum-33 (NSPM-33): Presidential Memorandum on U.S. Government-Supported Research and Development National Security Policy

White House OSTP / NSTC Research Security Subcommittee|
ActiveFederal

A Presidential Memorandum issued in January 2021 to strengthen protections of U.S. Government-supported R&D against foreign government interference and exploitation. It focuses on ensuring full disclosure of potential conflicts of interest and commitment by recipients of federal R&D and requires research institutions receiving over $50 million in federal R&D funding to certify they operate a research security program covering cybersecurity, foreign travel security, insider threat awareness, and export control training. As of November 2025, federal agencies continue to coordinate and work to implement this requirement for awardee institutions.

Recommended Practices for Strengthening the Security and Integrity of America's Science and Technology Research Enterprise

NSTC Research Security Subcommittee|
ActiveFederal

A supplement to NSPM-33 outlining recommendations for research organizations to enhance research security and integrity. Categories include: Demonstrate organizational leadership and oversight; Establish an expectation of openness and transparency; Provide and share training, support, and information; Ensure effective mechanisms for compliance with organizational policies; and Manage potential risks associated with collaborations and data.