White House Issues Research Security Guidelines to Agencies and ‘Covered Institutions’

On July 9, the Biden Administration issued a memorandum on Guidelines for Research Security Programs at Covered Institutions. The document provides guidance to federal research agencies as they implement research security certification requirements set by National Security Presidential Memorandum (NSPM)-33, the hallmark research security policy that has been in development since early 2021, and the CHIPS and Science Act of 2022. Under these acts, the White House Office of Science and Technology Policy (OSTP) is responsible for “developing a ‘standardized requirement’ for ‘uniform implementation’ across federal research agencies.” This latest memo serves as that standardized requirement. 

Informed by input received from inside and outside the government, the guidelines include a standard definition of “covered institution,” which is an institution of higher education, a federally-funded research center, or a nonprofit research institution that receives more than $50 million per year in federal research funding. Under agency policies, covered institutions will be required to certify that they have research security programs in place that address cybersecurity, foreign travel, research security training, and export control training (the memo provides details on each). In addition, federal research agencies are required to ensure that research security programs at covered institutions “do not result in targeting, stigmatization, or discrimination against individuals on the basis of race, color, ethnicity, religion, sex… disability, or genetic information,” and allow for flexibility in developing institutional programs, reduce administrative burden, and minimize impact to smaller institutions.

Federal research agencies are directed amend their research security polices to reflect the guidelines in the memo within six months (~January 2025), with the revised policies taking effect within six months after the final plans have been submitted to the White House. Stay tuned to COSSA’s coverage.