Research Security Program

Research Security Program

About

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Provisions of National Security Presidential Memorandum 33 (NSPM-33) and the CHIPS and Science Act of 2022 (CHIPS Act) require Institutions receiving over $50 million per year in federal research funding must operate under a compliant Research Security Program.

In response, UVM has implemented Research Security Program that is collaborative among various offices at the University.

If you have questions, please contact the Executive Director of Research Administration and Integrity.

Below are the 4 required components of UVM’s research security program.

1. Cybersecurity

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Team Lead: Scott Carbee, Chief Information Security Officer

Cybersecurity is an expansive and complex area, and its scope extends well beyond research. Research taking place under government contracts may be subject to additional security controls. 

The following resources are helpful starting points.

2. Foreign Travel Security

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Team Lead: Erin Fitzgerald, Director, Disbursements

UVM has partners with Collegiate Travel Planners (CTP) to provide our affiliates with travel booking and support services. The use of CTP also allows UVM to fulfill our duty of care for our travelers by offering risk-mitigating features and improved reporting. 

The use of Collegiate Travel Planners (CTP) by faculty and staff for domestic and international airfare and domestic rental car transactions is mandatory.   

For more detail see UVM’s International Travel webpage.

3. Research Security Training

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Team Lead: Brian Prindle, Executive Director Research Administration and Integrity

Investigators will learn key concepts of research security and how to recognize situations that may indicate undue foreign influence.

All Investigators and key personnel must complete this training.

Research Security Training modules are available online at CITI.

Beginning October 1, 2025, we anticipate putting a hard stop on the SPA award set-up process until all Investigators and key personnel on the award complete Research Security Training.

For further details and navigation to CITI go to our Research Security Training webpage. 

4. Export Control Training

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Team Lead: Victoria Jones, Research Compliance Officer

The UVM Export Control Program maintains responsibility for establishing awareness of the export control policy, procedures, and guidelines designed to meet the requirements of the various federal laws governing the export of controlled technology, equipment, software, information, or services to a foreign person or to a foreign country.

Regulatory Background: NSPM-33, CHIPS Act, OSTP

Information

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Federal funding Rules, Restrictions, Conditions and Research Security requirements are being introduced into the Research enterprise ecosystem.

These new rules and regulations are a result of National Security Presidential Memorandum 33 (NSPM-33) and the CHIPS and Science Act of 2022

National Security Presidential Memorandum 33 (NSPM 33)

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Released in January 2021

NSPM-33 directs federal agencies to take action and strengthen protections of United States Government-supported Research and Development against foreign government interference by improving research security and research integrity. 

  • Standardization of Proposal Disclosure Forms, Formats, Requirements
  • Consequences for Violation of Disclosure Requirements
  • Digital Persistent Identifiers (ORCID ID)
  • Digital Biosketches (SciCV)
  • Agency Risk Mitigation when Foreign Engagement is Disclosed
  • Require Grantees and Contractors to have a Research Security Program

CHIPS and Science Act, Public Law No: 117-167

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Released in August 2022 

  • Individual and Institutional certification confirming Investigators have completed Research Security Training (CHIPS Act Section 10634).
  • Individual certification confirming Investigators are not involved in a Maligned Foreign Talent Recruitment Programs (CHIPS Act Section 10632).
  • Institutional disclosure of certain foreign gifts and contracts associated with a foreign country of concern (CHIPS Act Section 10339B).

Office of Science and Technology Policy

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COGR Issue Guidance in 2024

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