National Security Presidential Memorandum 33 (NSPM-33) Implementation

Disclosure requirements are two-fold and are intended to address COIs and/or COCs:

1. Annual completion of the COI/COC disclosure, along with necessary updates within 30 days as applicable, in Nuramp;
2. Ensuring accurate and updated biosketches, CVs, and Other Support is provided to each applicable federal sponsor to address any COIs and/or Conflicts of Commitment. UNL researchers should partner with the Office of Sponsored Programs to ensure this is completed.

The principles that make a robust UNL COI/COC program important are of significance to our federal sponsors and the University of Nebraska (NU) Board of Regents. Updates to the UNL COI/COC Policy and disclosure occurred in 2024 to align with NSPM-33 needs along with NU Board of Regents policies and NU Executive Memorandum 36.

As stewards of public funds and resources, it is critical for UNL employees to transparently disclose information regarding actual, potential, or perceived COIs/COCs. A COI/COC is a situation, not a behavior. Disclosing this information does not mean wrongdoing has occurred. Disclosure allows your supervisor(s) and UNL compliance staff to fairly and independently determine if a conflict exists that requires some form of management.

Violation of disclosure requirements may have criminal, civil, and/or administrative consequences. UNL research personnel are ultimately responsible for ensuring that they make any necessary disclosures required by sponsors and internal policy and follow any prescribed plan for the management, reduction, or elimination of a real or perceived conflict or interest/commitment. Failure to disclose or providing false, misleading, or incomplete information is a violation of University Policy and may have significant consequences with federal sponsors.

The ORCID iD is an open, nonprofit registry that provides researchers unique identifiers that can be used to consistently and accurately find researchers and their scholarly activities. The identifiers are unique and persistent, allowing researchers and their work to be tracked through entire careers, regardless of name changes or having similar names to other scientists.

Many publishers, including Wiley, Springer Nature and PLOS have started to require ORCID identities as part of the publication submission process. Also, numerous federal funding agencies strongly encourage their use.

Registration is fast and free, and researchers can link an ORCID profile to the university’s single sign on system. Once registered, researchers can search databases like CrossRef and Scopus for publications to link to ORCID profiles.

Registration for an ORCID identity is available online.

DPIs are now required for research personnel receiving federal funding. The UNL Libraries can assist researchers with this process.

Federal sponsors and agencies have long expected certain compliance requirements to be met as part of receipt of funding and the responsible conduct of research. It should be no surprise to the UNL research community that consequences for violations of NSPM-33 requirements can occur. Depending on the nature of the violation, agencies may consider a range of consequences. Examples include, without limitation:

• Suspension or termination of funding
• Required re-training or other mitigation strategies
• Civil and criminal penalties under US federal and State laws may apply
• Additionally, federal agencies may now also share information. Thus, a violation with one federal sponsor may be reported and impact or cause action from additional federal sponsors for both individuals and the university.

While there are no specific action items on this section, the overall conduct of the work and ensuring that DPIs, transparency/disclosure, and training requirements are met are critical in ensuring individuals and our university do not face consequences for non-compliance with NSPM33 expectations.

Expectations for the establishment of research security programs include the following key areas:

• Cybersecurity: OR&I, NU ITS, and RCIS have been working for some time to ensure our cybersecurity practices in research environments meet not only the expectations of federal sponsors but also the expectations of the University of Nebraska. Research personnel are reminded to follow:
  • NU Executive Memorandums 16, 41, and 42
  • Best practices for Research Security & Research Data Security Checklist
  • Budgetary needs: in some cases Medium and High levels of security require additional budgeting and planning to comply with security expectations. Researchers should consider their budget needs at the proposal stage and through the life of the project, including the need for long-term storage and retention options.
• Foreign travel security: If research personnel are traveling for university related business purposes, they must follow all university and federal sponsor expectations for foreign travel approvals and security. UNL RCIS has updated NuRamp notifications for all international travelers to include information on foreign travel security best practices. The university will not reimburse personnel who do not comply with travel policies.
• Export control training: UNL has already been meeting this expectation as applicable.
  • Anyone involved in an export controlled activity is required to complete Export Control training prior to engaging in such activities.
  • Export controls apply to a broad range of activities, entities, and people at UNL- not just those receiving certain federal funds or working in particular areas. Personnel must understand at least the basic areas where they may encounter export control requirements, such as travel, hosting visas, shipping, and activities on campus.
• Research security training: Requirements for meeting research security trainings are significant. Trainings created and offered by the lead agency in this area, NSF, are time-consuming (approximately 4 hours).

OR&I and RCIS have evaluated the available trainings both federally and internally while focusing on a couple of key items: reducing burden/confusion in various training needs and providing the best possible training for our campus. With this in mind, we have decided on a “Responsible Conduct of Research (RCR) for All,” approach.

Why have we decided to incorporate research security into an overall RCR training?

Research Security is one of the many pillars in the overall Responsible Conduct of Research (RCR). Some federal sponsors already require RCR  and research security training for non NSPM-33 purposes. Further, RCR core topics are frequently referenced and woven into other trainings and we believe this overall RCR/ethics training is important to our campus culture of responsibility and understanding of the larger research enterprise. While we have made this “RCR for All,” decision to satisfy NSPM-33 needs, we wish to reiterate that the value and importance of RCR training is not tied solely to NSPM33. RCR is– integrity in all we do, whether that is for a specific funding requirement or otherwise.

Thus, we have decided to more thoroughly incorporate research security training into a comprehensive Responsible Conduct of Research training. This will be available at the beginning of the Fall 2025 semester via a customized module in Learning Bridge. Research personnel will be required to complete a comprehensive RCR training every 4 years along with a brief refresher annually. In some cases, federal sponsors will not allow a proposal to be submitted and/or awarded without this training completed.