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R&I provides update on addressing federal requirements on research security

News for Researchers

Posted February 3, 2025 by Office of Research and Innovation

To align with updated federal requirements for safeguarding federally funded research, the University of Nebraska-Lincoln is reviewing and updating processes and procedures to ensure the university is compliant with the security directive. The Nebraska research community is urged to stay informed about these changes.

The U.S. government issued National Security Presidential Memorandum-33, NSPM-33, in January 2021 in response to increasing concerns about foreign government interference and exploitation of federal research funding. This directive requires federal agencies and departments to focus on four key security areas.  

Federal agencies and departments will begin to pass down these requirements in funding awards to institutions receiving at least $50 million per year in federal science and engineering support. UNL meets this threshold and will be required to comply.

Following the NSPM-33 directive, federal agencies issued finalized guidance in July 2024 on meeting these requirements. Federal funders must submit their plans to the Office of Science and Technology Policy and Office of Management and Budget within six months. After agencies finalize their plans, they must give covered institutions adequate time – up to 18 months – to implement their requirements.

Funders’ requirements are expected to be finalized by May. UNL investigators should be aware that these conditions may begin appearing in federal proposal solicitations beginning in late spring or summer on a case-by-case basis.

Since the release of NSPM-33 and additional guidance and clarifications, UNL’s Office of Research and Innovation has collaborated closely with Information Technology Services, University Libraries and the Office of Global Partnerships and Initiatives to identify potential gaps and solutions to address these requirements.

Disclosure requirements and standardization

Investigators are required to complete conflict of interest/commitment disclosures, along with updated biosketches and current, pending and other support. The Office of Sponsored Programs will ensure the appropriate documents are completed at the time of submission, but researchers and grant specialists are encouraged to familiarize themselves with the new guidance. The Council on Governmental Relations summarized the disclosure requirements in a helpful document that includes definitions and comparisons.

Digital persistent identifiers

Sponsored researchers will be required to utilize digital persistent identifiers such as ORCID. UNL has an institutional ORCID membership, and University Libraries can assist researchers with creating or retrieving an ID.

Research security programs at federally funded institutions

UNL is required to address research security training, cybersecurity, foreign travel tracking/security and export control training. UNL was at least partially compliant with each of these areas at the time the final requirements were released. As of January 2025, R&I awaits funders’ requirements to determine the next steps for full NSPM-33 compliance.

Information sharing across agencies

The National Science Foundation has been leading discussions and issuing guidance for these requirements, with the goal of harmonizing procedures across agencies. More information will be shared with the Nebraska research community as it becomes available.

UNL largely meets these requirements; however, R&I is working to identify gaps and make necessary updates. More information will be communicated soon.

For questions about NSPM-33 requirements, please contact Alian Kasabian, research data and security liaison.


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