On July 9th, 2024, the Office of Science and Technology Policy (OSTP) in the White House released its long-awaited guidance to standardize requirements across federal research agencies when requiring “covered institutions” to establish and certify their comprehensive research security programs. The guidance addresses risks posed by foreign entities of concern, while also emphasizing the need for continued openness of U.S. research and development and rejecting xenophobia and discrimination.
Key Updates on OSTP’s Research Security Guidance for Research Institutions
Building on previous guidance for the implementation of NSPM-33 and directives in the CHIPS and Science Act, the guidance standardizes the definition of a “covered institution” to include: institutions of higher education (IHEs), federally funded research and development centers (FFRDCs), and non-profit research institutions that receive federal science and engineering support exceeding $50 million per year.
Federal agencies will have 6 months to update their policies and submit their plans to OSTP and the Office of Management and Budget (OMB). Agency policies must be effective within six months of submission to the White House. Covered institutions will have up to 18 months from the effective date of agency plans to implement new requirements. The guidance directs agencies to give special consideration to institutions in EPSCoR jurisdictions, HBCUs, and other MSIs that may be less-resourced. Covered institutions will need to certify they have implemented their own research security programs, which must include:
- Cybersecurity
- Foreign travel security
- Research security training
- Export control training
Stay Updated on Federal Research Policies with McAllister & Quinn
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