COGR Responds to NSF’s Request for Response to Dear Colleague Letter: Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization

COGR submitted a letter to the National Science Foundation's (NSF) regarding the proposed Research Security and Integrity Information Sharing Analysis Organization (RSI-ISAO). COGR expresses strong support for the development of RSI-ISAO, emphasizing the need for trust, transparency, and voluntary institutional participation without an enforcement or intermediary role. The letter highlights the importance of RSI-ISAO as a neutral forum, transparent in its operations, and clear in the information it gathers and disseminates. COGR's feedback includes a call for the RSI-ISAO charter to recognize risk-based assessment and mitigation strategies, and to provide practical tools and clear, actionable threat information tailored to varying risk levels among international collaborators. COGR’s comments further address the types of daily research security issues encountered by institutions, particularly the complexities in managing collaborations with entities in high-risk countries like China, and the need for explicit, risk-based federal guidance. It recommends that RSI-ISAO provide up-to-date, detailed lists and resources, robust analytical tools, and a safe space for open communication. Additionally, the letter raises concerns regarding potential participation barriers if RSI-ISAO adopts a fee-based model, which could disadvantage smaller research institutions. COGR concludes by supporting EDUCAUSE’s recommendations that RSI-ISAO should leverage existing cybersecurity information sharing infrastructures to avoid redundancy, underscoring the alignment and prioritization of RSI-ISAO’s role in enhancing research security across the academic landscape.