An Update on Research Security: Streamlining Disclosure Standards to Enhance Clarity, Transparency, and Equity
Morgan Dwyer, Principal Assistant Director for National Security,
Office of Science and Technology Policy
Christina Ciocca Eller, Assistant Director of Evidence and Policy and Co-Chair of the National Science and Technology Council Subcommittee on Research Security, Office of Science and Technology Policy
Ryan Donohue, AAAS Science and Technology Policy Fellow and Senior Policy Advisor, and Member of the National Science and Technology Council Subcommittee on Research Security,
Office of Science and Technology Policy
One of America’s greatest strengths is its scientific and technological innovation, fueled over time by Federal investments in research and development (R&D). From the fundamental to the applied, U.S.-supported research has transformed our world and has made our communities safer, healthier, stronger, and more equitable.
The American research culture is intentional in its strong commitment to openness. Yet maintaining that open research culture also requires being clear-eyed that certain governments seek to exploit our openness and disrupt the integrity of our research. Such threats require the Federal government, in collaboration with the research community, to take protective actions to mitigate research integrity risks without compromising the values that distinguish the U.S. research enterprise: openness, transparency, honesty, equity, fair competition, objectivity, and democratic participation.
The Biden-Harris Administration is committed to strengthening research security without compromising these core values. “Research security” here refers to safeguarding the U.S. research enterprise against the misappropriation of research and development to the detriment of national or economic security, related violations of research integrity, and foreign government interference. Since January 2021, the White House Office of Science and Technology Policy (OSTP), together with colleagues across the federal government, have worked to shape the implementation of National Security Presidential Memorandum (NSPM)-33, a bipartisan research security policy intended to protect U.S. government supported research and development.
NSPM-33 directs a series of actions for Federal research agencies, with an emphasis on developing standardized policies and practices for disclosing information to assess conflicts of interest and conflicts of commitment among researchers and research organizations applying for Federal R&D awards. Standardized disclosures are an optimal approach for increasing clarity, transparency, and equity while streamlining requirements and decreasing burden to the research community. They also enable Federal science funding agencies to identify potential conflicts of interest and commitment more rapidly and accurately, enabling them to make funding decisions that mitigate potential threats to research security and integrity.
After substantial engagement with the U.S. research community, OSTP issued implementation guidance describing our ongoing efforts and outlining commitments in the areas of i) engaging regularly with the research community and other stakeholders to share information, ii) standardizing disclosure information to assess potential conflicts of interest and conflicts of commitment, iii) coordinating agency policy development for researcher digital persistent identifiers, and iv) developing research security program standards.
Now, after months of intensive collaboration across Federal science and security agencies, as well as regular engagement with the U.S. research community,the National Science and Technology Council’s Subcommittee on Research Security (SRS)—the group leading the Administration’s research security work—has successfully developed standardized data fields and instructions for disclosure of information to assess potential conflicts of interest and conflicts of commitment among researchers applying for grants and co-operative agreements with Federal science funding agencies. All of the Federal science funding agencies have agreed to move towards adopting standardized formats.
Federal science funding agencies have also agreed that the draft standardized disclosure materials are ready for public comment and review. The public comment and review process will be led by the Office of Information and Regulatory Affairs at the Office of Management and Budget, in partnership with the National Science Foundation (NSF). Please check this Federal Register notice of public comment, or contact us at firstname.lastname@example.org with any questions. We look forward to public feedback on our progress. Below, we share further progress on engagement with the U.S. research community and the issue of research disclosures. We also provide updates in our multi-pronged efforts to safeguard the integrity of Federally funded research, while preserving core values of the Biden-Harris Administration during the continued implementation of NSPM-33.
As NSPM-33 makes clear, it is imperative to engage regularly with security-focused departments and agencies to understand and assess the evolving risks related to research security and integrity. In addition, both the language of NSPM-33, and the values advanced by the Biden-Harris Administration regarding the U.S. science and technology environment, underscore the importance of regular engagement and information sharing with members of the research community.
The SRS was grateful to learn from the nearly 40 organizations that visited the Engagement Hours over the course of the spring. These organizations represent a diverse array of contributors to the U.S. research ecosystem, including public and private colleges and universities around the country, professional organizations representing a variety of scientific disciplines, non-profit organizations dedicated to strengthening research security and integrity, and scholarly and advocacy organizations representing the Asian American, Pacific Islander, and Native Hawaiian communities, in particular. The ideas, concerns, and questions raised by these organizations are accounted for in our continued development and implementation of NSPM-33 policies, reflecting the commitment of OSTP and members of the SRS to working together with the U.S. research community.
The SRS anticipates releasing a public report this fall capturing the recommendations made and our lessons learned. We also anticipate additional Engagement Hours in the future. We are particularly interested in hearing from rural, historically-Black, Hispanic-serving, and Tribal colleges and universities, as well as other minority-serving institutions, regional colleges and universities, and community colleges. Please send us an email at email@example.com to express interest in participating.
The work to develop standardized disclosure formats began with NSPM-33, but has been expedited since OSTP’s issuance of implementation guidance in January 2022. The guidance conveys the consensus of Federal science and security agencies: the U.S. research enterprise works best when its participants are candid and open about disclosing affiliations that may pose potential conflicts of interest or commitment and thus interfere with the integrity of their own or others’ research. Toward this end, OSTP called upon agencies to work together to develop a disclosure process that is as clear and straightforward as possible for agencies, research organizations, and researchers.
These standardized formats serve several purposes. They lower burden by allowing researchers to use the same straightforward forms for every application, without having to input different information for each funding agency application. They also facilitate compliance and accuracy in reporting. This in turn promotes better information fidelity among agencies to ensure the integrity of research is preserved. Standardized formats ensure equity across researcher award systems through collection of the same information. Finally, they provide clarity to systems developers like agency grant management teams and developers of tools like digital persistent identifiers (PIDs, also known as DPIs), so they can know precisely what information is required, and build tools that make the process of applying easier.
Standardized disclosures allow all Federal science funding agencies to adopt these standards so that researchers can expect to provide the same information no matter where they apply for research funding. We recognize the wide variability among agency missions and unique regulations and statutory requirements, so agencies may require additional disclosures as needed. However, the core standards will be unified. We commend agencies for their willingness to navigate their complex systems to develop this whole-of-government product for the sake of the researchers they fund, and look forward to working with them as we move to the next phase.
Digital Persistent Identifiers
NSPM-33 describes the requirement for each Federal science funding agency to develop policies regarding requirements for individual researchers to be registered with a digital persistent identifier (PID, also known as a DPI). To address the substantial legal, policy, technical, and implementation considerations that may be required for agencies to develop an effective researcher PID policy, SRS recently convened a series of interagency discussions, led by OSTP and the Department of Energy.
These discussions were designed to share information, best practices for, and lessons learned about researcher PID policy development and implementation. From March through May, this PID subgroup, comprised of nearly every science funding agency, met seven times. As the discussions have concluded, the subgroup is developing an internal toolkit to equip agencies with better information on how to approach their policy development and implementation.
The long-term vision for implementing the NSPM-33 provision for PIDs is that researchers could maintain their PID, much like one would a CV, by keeping their PID up-to-date with important information such as funding sources, research outputs, and, for the purposes of NSPM-33 implementation, affiliations. Researchers could then sync their PID to any Federal award application system, thus reducing burden and potential good-faith mistakes. As mentioned above, key to meaningful implementation is standardization of disclosure data fields to make crystal clear to both agencies and PID developers what is required to facilitate ease of integration.
Research Security Programs
To strengthen research security programs, SRS has worked to clarify and further specify the requirements detailed in the NSPM-33 implementation guidance, as well as the provisions described in the CHIPS and Science Act of 2022. As a reminder, NSPM-33 directs Federal science funding agencies to require that research organizations receiving more than $50 million in Federal science and engineering funding for two consecutive years certify that they have in place a research security program that meets the standards laid out by NSPM-33 and the related implementation guidance. These standards include four particular areas of research security programs: general research security training, foreign travel security, cybersecurity, and export security, as appropriate. The CHIPS and Science Act extends requirements regarding the research security training portion of research security programs to all covered individuals applying to receive Federal science and engineering funding as employees of institutions of higher education or other research organizations.
To ensure that requirements for research security programs are met with minimal implications for cost and administrative burden to research organizations, the Federal government will specify the requirements in even greater detail than outlined in the implementation guidance. We anticipate that the draft research security program standards will be available for a formal period of public comment in the fall.
The Federal government also will provide technical assistance to comply with requirements regarding research security programs. Specifically, several Federal agencies, including NSF, the Department of Defense, the Department of Energy, and the National Institutes of Health, have joined together to support cooperative agreements wherein collaborators outside of the U.S. Government will develop digital training content to meet the required standards, which other research organizations may use if they choose. Learn more here.
In our mission to secure the Nation’s R&D, OSTP will continue to partner with SRS toward standardization of both the disclosure process and requirements for institutional research security programs; we will actively and consistently engage with the scientific community to help us understand the effects of these policies; and we will ensure that the U.S. research culture can reach its fullest potential through openness, equity, security, and integrity.