Reference Library

Published July 10, 2025. Includes NSF implementation of three new requirements (and three existing ones) in alignment with the CHIPS and Science Act and NSPM-33. The requirements, effective October 10, 2025, include: a. Recipient institutions must maintain supporting documentation for foreign activities reported as current and pending (other) support, b. Senior/key personnel must certify they have completed research security training (RST) within 12 months prior to proposal submission; Recipient institutions' Authorized Organizational Representative (AOR) must certify that all senior/key personnel have completed required RST and that the institution has a plan to provide appropriate training, c. AORs at institutions of higher education (IHEs) must certify that, absent a waiver granted by the NSF Director, the IHE does not maintain a contract or agreement between the institution and a Confucius Institute.

The CHIPS and Science Act of 2022 directs federal research funding agencies to establish a policy that requires each covered individual (CI) listed in an R&D proposal to certify that they are not a party to a MFTRP in the proposal submission and annually thereafter for the duration of the award. NSF was the first federal agency to implement this certification via the common federal biosketch and current and pending support forms in May 2024. NSF began rolling out the annual certification on June 7, 2025, for all PIs and co-PIs named on an NSF award made on or after May 20, 2024. NSF is making sample contracts available that meet the parameters of a MFTRP. Contract examples and frequently asked questions can be found on the NSF website under MFTRPs.

June 2024. NSF initiated a proposal risk review process similar to that of DoD but with some notable differences. NSF's process will focus on critical technologies, beginning with a pilot of quantum technologies proposals in FY25, expanding to other key technologies in phase 2, and scaling up for all key technologies identified in the CHIPS and Science Act in phase 3. NSF will evaluate Three Criteria: 1. Appointments and positions with U.S. proscribed parties (e.g., U.S. BIS Entity List) and currently party to a MFTRP; 2. Non-disclosures of appointments, activities, and financial support; and 3. Potential foreseeable national security applications of the research. NSF will consider only current foreign appointments and affiliations and is not considering co-authorship in risk assessment.

A summary of the NSF-funded workshop 'Responsible Collaboration Through Appropriate Research Security' held at Rice University's Baker Institute for Public Policy in May 2024. Discusses challenges and opportunities in the emerging field of RoRS and provides recommendations to guide NSF's new RoRS program.

A March 2024 report commissioned by NSF and issued by the JASON group. Recommends NSF adopt a dynamic approach for identifying potentially sensitive research topics as they arise and weigh the balance between the protective benefits and the unintended negative consequences of controls on sensitive research. It is suggested that the identification of sensitive projects proposed to NSF occurs most naturally before peer or panel review. Specific mitigation strategies for sensitive research projects should be negotiated and agreed upon by the principal investigator (PI), NSF, and the institution and be proportionate to the assessed risk, relative to the associated costs.

A Dear Colleague Letter issued by NSF in May 2023 regarding the NSPM-33 Research Security Programs Standard Requirement.

A March 2023 report issued by JASON and commissioned by NSF. Provides definitions of Research Integrity as adherence to accepted values and principles -- objectivity, honesty, openness, accountability, fairness, and stewardship -- that guide the conduct of research. Research Security is protecting the means, know-how, and products of research until they are ready to be shared. JASON suggests research security does not vary across disciplines, but the consequences of breaches in research security and the measures taken to prevent breaches will differ. Key points include an emphasis on training researchers on risks in international collaborations, the need to encourage collaboration with international organizations that are also concerned with research security, and avoiding creating a reputation of racial profiling or using the research security programs to disadvantage anyone based on ethnicity or nationality.

February 2023. Outlines advanced monitoring and verification activities of NSF proposals and awards. The guidelines largely serve to provide transparency and identify guardrails NSF has put in place around the use of data analytics to monitor and validate information disclosed (e.g., in biosketches and current and pending support). For example, the activities are not investigative and cannot be incorporated into the merit review process. Sources of information include SCOPUS, Web of Science, and the U.S. Patent and Trademark Office Patent Database.

The NSF Proposal and Award Policies and Procedures Guide (NSF 23-1, January 2023). Post-award Disclosure of Current Support and In-Kind Contribution Information: PAPPG Chapter II.D.2.h(ii).

Directs NSF to collect annual summaries of foreign financial support from universities. The provision establishes a reporting threshold of $50,000 or more in [cumulative] financial support, including gifts and contracts, received directly or indirectly from a foreign country of concern (China, Russia, North Korea, and Iran at the time the law was enacted), or any other country determined to be a concern by the Secretary of State. This is in addition to the reporting of gifts and contracts from all foreign countries with a cumulative value of $250,000 or more via the Higher Education Act and Department of Education.

Establishes an Office of Research Security, Strategy, and Policy within NSF.

Establishes a Chief of Research Security position within the NSF Office of the Director to manage the Office of Research Security and Policy.

Directs [NSF] to develop an online resource to inform institutions and researchers of security risks and best practices and explain Foundation research security policies.

Authorizes the NSF OCRSSP, in coordination with the Office of Inspector General (OIG), to conduct risk assessments, including through the use of open-source analysis and analytical tools, of R&D award applications and disclosures to NSF.

Expands the requirement for RCR training to include faculty and other senior personnel on [NSF] awards and expands the scope of such training to include mentoring training and training to raise awareness of research security risks as well as Federal export control, disclosure, and reporting requirements.

Directs [NSF] to establish a research security and integrity information sharing analysis organization to enable the research community to share information, identify research security risks, and implement risk assessment and mitigation best practices and procurement of a non-government organization to run this center. The SECURE Program, including the SECURE Center and SECURE Analytics, were implemented to answer this call.

Places restrictions on eligibility for NSF R&D funding for institutions that host or support Confucius [or Confucius-like] institutes.

Signed January 3, 2020. Section 223 mandates disclosure of funding sources in applications for federal R&D awards and holds universities accountable for ensuring faculty awareness. Section 1299C is an amendment to FY 2019 NDAA Section 1286 requiring designation of an official responsible for liaising with academic institutions and briefing them on espionage risks. Section 1062 restricts DoD and NSF funds to institutions hosting a Confucius Institute. Section 9907 prohibits any funds for microelectronics initiatives to a foreign entity of concern.

NSF's formal response to the JASON Group's report on Fundamental Research Security, outlining how the Foundation plans to address the report's findings and recommendations.

A December 2019 report from the JASON Group commissioned by NSF. The report outlines that concerns of foreign influence can be addressed within the framework of research integrity and, in addition, that the benefits of openness in research and of the inclusion of foreign researchers dictate against measures that would restrict fundamental research. The report includes questions for researchers to consider when entering a collaboration [Section 7.3 Assessment Tools: pages 34-36].

NSF's research security portal providing access to policies, forms, training resources, and guidance related to research security at the National Science Foundation.