Research Security Program
About
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
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.
- Enterprise Technology Services (ETS) and the Vermont Advanced Computing Center (VACC) provide support to all researchers at UVM including data storage, safeguarding, infrastructure support and user support.
- A good place to start is at Research Computing.
- Review UVM's Data Risk Classification Matrix.
- For data storage options see UVM Storage Solutions.
- For assistance, not sure what to do, contact iso@uvm.edu.
2. Foreign Travel Security
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
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
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
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)
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
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
- July 9, 2024, OSTP Memo to Federal Agencies that provides the Guidelines for Research Security at Covered Institutions.
COGR Issue Guidance in 2024
- July 16, 2024, COGR publishes an Overview of OSTP Guidelines for Research Security
- For additional information about all the federal regulations see COGR’s Quick Reference Table of Current & Upcoming Federal Research Security Requirements.