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NSPM-33 interim implementation guide defines research security as safeguarding “the research enterprise against misappropriation of research and development to the detriment of national or economic security, related violations of research integrity, and foreign government interference.” 

 As specified in , a research security program must include: 

• A cybersecurity program consistent with the National Institute of Standards and Technology guidance 

• Foreign travel security that includes periodic training for covered individuals and report requirements 

• Research security training for covered individuals and an institution’s certification of individuals’ completion of such training 

• Export control training for covered individuals who perform research and development involving export-controlled technologies and processes for reviewing foreign sponsors, collaborations, and partnerships 

Under the final implementation guidance, federal research agencies may develop additional requirements for research security programs beyond the four elements above. 

A “Covered Individual”, is defined as an individual who: 

• Contributes, in a substantive, meaningful way to the scientific development or execution of a federally funded research project; or 

• Is designated as a Covered Individual by a Federal research funding agency 

Note: The definition of a Covered Individual is based on their contribution to the project as defined above and is not related to the title of the individual. At UM, a Covered Individual could be a faculty member, research scientist, researcher, visiting scientist, student (undergraduate or graduate), post-doctoral fellow, etc., regardless of of whether, they are paid or unpaid. Similarly, federal regulations and federal agencies use different terms such as, principal investigators (PIs), co-PIs, project directors, senior/key personnel. 

You can take the training and get information by selecting the links above or by the hyperlinks below.. There is training for research security, foreign travel and export control. Continue to the bullet points below to help determine which training courses are required for you. 

• All covered individuals and key personnel must take the Research Security Training. 
• is required for research awards that are responsible for federally controlled devices or whose products meet export control requirements. Export control training is required for all principal investigators and their lab members and anyone else identified in the request for proposals, notice of funding opportunity, or award terms and conditions whose projects require a Technology Control Plan (TCP). A TCP is a living document that outlines the means by which information and technology controlled under ITAR, and in some circumstances, the EAR, will be protected.  

• Foreign Travel Security Training is for all principal investigators (PIs), co-principal investigators (co-PIs), senior/key personnel, program directors (PDs), co-program directors (co-PDs), project managers, and anyone else identified in the request for proposals, notice of funding opportunity, or award terms and conditions must complete Foreign Travel Security Training if they travel internationally for organization business, teaching, conference attendance, or research purposes, regardless of whether the travel will be charged to a sponsored project 

Universities are required to have a research security program to comply with federal regulations, such as the National Security Presidential Memorandum 33 (NSPM-33). NSPM-33 mandates that institutions receiving federal science and engineering support in excess of $50 million per year establish and operate a research security program. This is to protect U.S.-funded scientific research from undue foreign influence and intellectual property theft.

Responsible conduct of research is related to research integrity and security but covers a broader range of topics, such as the ethical treatment of human subjects. Research security training focuses on providing researchers with clear guidelines and effective strategies to protect against existing and emerging research security threats.

Research security training helps to guard against several risks, including but not limited to theft or misuse of research data, improper use of intellectual property, and the potential dissemination of untrustworthy scientific results. Building a culture of research security protects research advances from misuse and misappropriation. 

Research security is a shared responsibility across all academic disciplines and university functions. Faculty often work on cross-disciplinary research and scholarly endeavors, including teaching activities. Through these activities, an individual may be exposed to critical or emerging activities. In addition, many of the research security concepts are portable to general research and daily life, such as cybersecurity and recognizing when an individual's stressors (e.g., finances) could adversely impact their decision-making in the workplace, threatening the integrity of the individual or the institution. 

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Award personnel - The term "award personnel" means principal investigators and co-principal investigators, faculty, postdoctoral researchers, and other employees supported by a grant, cooperative agreement, or contract under Federal law. 

Conflict of commitment – Situation in which an individual accepts or incurs conflicting obligations between or among multiple employers or other entities. Many organizational policies define conflicts of commitment as conflicting commitments of time and effort, including obligations to dedicate time in excess of organizational or research agency policies or commitments. Other types of conflicting obligations, including obligations to improperly share information with, or to withhold information from, an employer or research agency, can also threaten research security and integrity, and are an element of a broader concept of conflicts of commitment used in this document. 

Conflict of interest – Situation in which an individual, or the individual’s spouse or dependent children, has a significant financial interest, or financial relationship that could directly and significantly affect the design, conduct, reporting, or funding of research. 

Controlled unclassified information (CUI) – Information that requires safeguarding or dissemination controls consistent with applicable laws, regulations, and Government-wide policies, but is not classified. 

Covered individual or Senior/key personnel – an individual who (a) contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a federal research agency; and (b) is designated as a covered individual by the federal research agency concerned. Consistent with NSPM-33, this means principal investigators (PIs) and other senior/key personnel seeking or receiving federal research and development funding (i.e., extramural funding) and researchers at federal agency laboratories and facilities (i.e., intramural researchers, whether or not federally employed), including Government-owned, contractor-operated laboratories and facilities. 

Current and pending research support – (a) All resources made available, or expected to be made available, to an individual in support of the individual’s research and development efforts, regardless of (i) whether the source is foreign or domestic; (ii) whether the resource is made available through the entity applying for a research and development award or directly to the individual; or (iii) whether the resource has monetary value; and (b) includes in-kind contributions requiring a commitment of time and directly supporting the individual’s research and development efforts, such as the provision of office or laboratory space, equipment, supplies, employees, or Ñý¼§Ö±²¥. This term has the same meaning as the term Other Support as applied to researchers in NSPM-33: For researchers, Other Support includes all resources made available to a researcher in support of and/or related to all of their professional R&D efforts, including resources provided directly to the individual rather than through the research organization, and regardless of whether or not they have monetary value (e.g., even if the support received is only in-kind, such as office/laboratory space, equipment, supplies, or employees). This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, gifts provided with terms or conditions, financial support for laboratory personnel, and participation of student and visiting researchers supported by other sources of funding. 

Digital persistent identifier (DPI or digital PID) – A digital identifier that is globally unique, persistent, machine resolvable and processable, and has an associated metadata schema. Consistent with NSPM-33, digital persistent identifiers for individuals are used to disambiguate and identify an individual person. 

Export Control - Export Controls are Federal Laws and regulations that govern the transfer or disclosure of goods, technologies, software, services, and funds originating in the U.S. to persons or entities in foreign countries or non- U.S. persons even if located in the U.S. 

Federal Research & Development (R&D) - funding constitutes all funding for scientific research and development provided by the federal government. Research means a systematic investigation—including research, development, testing, and evaluation—designed to develop or contribute to generalized knowledge. Activities that meet this definition constitute research for purposes of this policy, whether or not they are conducted or supported under a program that is considered research for other purposes. For example, some demonstration and service programs may include research activities. 

Federal research agency or Research agency – Any Federal department or agency with an annual extramural research expenditure of over $100,000,000. This term has the same meaning as “funding agency” in NSPM-33. 

Foreign Country of Concern - The term foreign country of concern means:  

(a) A country that is a covered nation (as defined in 10 U.S.C. 4872(d)); and  

(b) Any country that the Secretary, in consultation with the Secretary of Defense, the Secretary of State, and the Director of National Intelligence, determines to be engaged in conduct that is detrimental to the national security or foreign policy of the United States.  

Foreign government-sponsored talent recruitment program – Effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or Ñý¼§Ö±²¥ (regardless of citizenship or national origin, or whether having a full-time or part-time position). Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation. 

Foreign Talent Recruitment Program - Effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or Ñý¼§Ö±²¥ (regardless of citizenship or national origin, or whether having a full-time or part-time position). 

Gift – Includes any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, license, special access, equipment time, samples, research data, or other item having monetary value. A gift also includes services as well as gifts of training, transportation, local travel, lodging, meals, research hours, whether provided in-kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has occurred. A gift by definition is given without expectation of anything in return. 

Insider threat – The potential for an insider to use their authorized access or understanding of an organization to harm that organization. This harm can include malicious, complacent, or unintentional acts that negatively affect the integrity, confidentiality, and availability of the organization, its data, personnel, or facilities. 

Malign Foreign Talent Placement Program - A program where the foreign country (often the government) targets the technology and location for an NTIC to acquire intellectual property to fill an identified knowledge gap to foster the goals of achieving national military and economic superiority. This program is implemented through foreign challenges, fellowships, and scholarship awards. 

Persistent Digital Identifier - A digital identifier that is globally unique, persistent, machine resolvable and processable, and has an associated metadata schema. Consistent with NSPM-33, digital persistent identifiers for individuals are used to disambiguate and identify an individual person. 

Research and Development (per 2 CFR 200.1) - means all basic and applied research activities and all development activities performed by a recipient or subrecipient. The term research also includes activities involving the training of individuals in research techniques where such activities use the same facilities as other research and development activities and where such activities are not included in the instruction function. “Research” is the systematic study directed toward fuller scientific knowledge or understanding of the subject studied. “Development” is the systematic use of knowledge and understanding gained from research to produce useful materials, devices, systems, or methods, including designing and developing prototypes and processes. 

Research integrity – The use of honest and verifiable methods in proposing, performing, and evaluating research; reporting research results with particular attention to adherence to rules, regulations, and guidelines; and following commonly accepted professional codes or norms.  

Research Organization – An entity that has applied for or received an R&D award from a federal research agency. This term has the same meaning as “entity” as defined in Section 223 of the NDAA for 2021. 

Research security – Safeguarding the 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.  

United States Government supported research and development – Includes R&D projects funded by the U.S. Government, in whole or in part; projects that use U.S. Government equipment or facilities for conducting R&D; and R&D projects in which U.S. Government employee and contractor personnel participate, regardless of the project’s funding source.