National Security Presidential Memorandum - 33 (NSPM-33)
What is NSPM-33?
NSPM-33 (National Security Presidential Memorandum-33) is a directive issued by President Trump on January 14, 2021 which has subsequently continued under the current Presidential administration, that requires all federal research funding agencies to strengthen and standardize disclosure requirements for Universities and researchers receiving federally funded awards. NSPM-33 also mandates the establishment of research security programs at research institutions receiving federal funds.
What is the purpose of NSPM-33?
NSPM-33 seeks to:
- protect intellectual capital, prevent research misappropriation, and ensure responsible management of U.S. taxpayer dollars while maintaining an open environment to foster research discoveries and innovation.
- safeguard the integrity of the U.S. R&D enterprise.
- reduce administrative burden by standardizing disclosure requirements and processes across all federal funding agencies.
What this means for Notre Dame Researchers?
It is helpful to think about these requirements in two categories: Disclosure Requirements and Requirements for Research Security & Training.
Standardized Requirements and Processes for Disclosure
One important objective of NSPM-33 is to standardize requirements and processes for disclosure of information (on Current & Pending, Biosketches, Progress Reports, etc..) across all of the federal funding agencies to the greatest extent possible. Ultimately, the goal is to have a single disclosure form that could be used for all of the federal agencies.
Examples of activities that may need to be disclosed include, but are not limited to:
- Academic, professional, or institutional appointments and positions, whether or not remuneration is received, and, whether full-time, part-time, or voluntary
- Postdoctoral scholars, students, or visiting scholars who are supported by an external entity, whether or not they work on federally-funded research projects
- Some Consulting activities
- Travel supported/paid by an external entity to perform research activities with an associated time commitment
- In-kind contributions
Research Security Program and Training
The University of Notre Dame will be required to establish a research security program and provide additional training to researchers. NSPM-33 requires a certification from research organizations awarded more than $50 million per year in total Federal research funding, that they have implemented a research security program that includes the four elements:
- Cybersecurity
- Foreign travel security (NDI Travel Registry)
- Research security training
- Export control training
The university will develop a formal research security training program based on agency guidance and existing export control training requirements will continue and may be modified or expanded as needed. The university will continue to work to update its policies and processes to remain in compliance with evolving federal requirements and assist researchers with understanding and disclosing required information.
For questions related to Research Security and expanded disclosure requirements, please contact Lori Doll, Research Policy, Compliance & Education Outreach Program Director, at compliance@nd.edu.
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