This update provides information about the Allen Institute’s response to NSPM-33.

What is NSPM-33?

NSPM-33 (National Security Presidential Memorandum-33) is a directive issued by the White House on January 14, 2021, that requires all federal research funding agencies to strengthen and standardize disclosure requirements for research institutions and researchers receiving federally funded awards. NSPM-33 also mandates the establishment of security programs at research institutions receiving federal funds to protect against foreign government interference and exploitation.

The purpose of NSPM-33 is 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.

There are two main areas of NSPM-33 that will impact researchers: Disclosure Requirements and 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, Biographical Sketches, Research Project Progress Reports, etc.) across all federal funding agencies. One of the goals of NSPM-33 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
• 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 Allen Institute’s research security program will be required to provide additional training to researchers. NSPM-33 requires a certification from research organizations with more than $50 million per year in total Federal research funding, confirming 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 Institute will modify its research security training program based on agency guidance and existing export control training requirements. Training will be modified or expanded as needed. The Institute 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 ResearchSecurity@alleninstitute.org.

Resources:

NSPM-33 Fact Sheet

NSPM-33 Guidance on Implementation