The National Science and Technology Council of the Office of Science and Technology Policy (OSTP) released the Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33) on National Security Strategy for United States Government-Supported Research and Development on January 4, 2022. This memorandum charged OSTP with “coordina[ting] activities to protect Federally funded R&D from foreign government interference, and outreach to the United States scientific and academic communities to enhance awareness of risks to research security and Federal Government actions to address these risks.”

Memorandum Requirements

The Memorandum requires that institutions have policies in place for disclosure and registration with a service that provides a digital persistent identifier for individuals supported or working on any federal research grant.

• Disclosure requirements and standardization: UH requires all employees to disclose conflicts of interest and conflicts of commitment, as well as disclosures related to procurement, export control laws, international relationships and technology transfer. The Conflicts of Interest and Related Disclosures page summarizes the requirements.
• Disclosure requirements of federal agencies on grants to address foreign influence are listed on the International Research
• Digital persistent identifiers: ORCID provides a free, unique, persistent identifier for individuals who engage in research, scholarship, and other innovative activities.

These provisions apply to all federally funded research and development, focused primarily, but not solely, on fundamental research.

NSPM-33 Requirements

NSPM-33 requires a certification from research organizations awarded in excess of $50 million per year in total Federal research funding that they have implemented a research security program that includes four elements. UH will establish a formal research security training program to address the four elements as follows:

1. Cybersecurity: For more information, go to UH Information Security’s Secure Research This page will be updated as the cybersecurity plan is implemented.
2. Foreign travel security
   1. Travel policies for faculty and staff traveling can be found on the Travel Policies
   2. Specific policies on international travel can be found on the International Research These policies include requirements to disclose and seek authorization in advance of international travel and, if deemed necessary, a mandatory security briefing.
   3. Assistance with electronic device security: UH recommends taking a “clean” laptop on foreign travel as taking laptops, encryption products, data, technology, blueprints, or other technical drawings to international conferences or visits to foreign institutions may fall under export controls.
3. Research security training:
   1. UH will offer the research security training that is currently being developed by four institutions that received funding from the National Science Foundation to address research security, disclosure, management and mitigation, and international collaboration.
4. Export control training:
   1. If research falls under export control, UH requires the completion of the Export Control module on CITI. Contact Dr. Laura Gutierrez (lgutierrez@uh.edu; 713-743-1897).

UH will continue to monitor the federal requirements and update our policies and procedures accordingly to educate and inform the research community about the disclosure of information.