The letter, authored by leading higher education associations, addresses Dr. Eric Lander, Director of the Office of Science and Technology Policy (OSTP), following a federal roundtable on implementing National Security Presidential Memorandum-33 (NSPM-33). The associations express support for safeguarding federally funded research while upholding the critical openness of the U.S. research ecosystem and avoiding actions that might fuel xenophobia or deter international academic collaboration. They emphasize the need for new research security requirements to strike a careful balance: promoting transparency and disclosure without unnecessarily hindering the recruitment and participation of international students and scholars.
The letter outlines specific recommendations and concerns related to the implementation of NSPM-33. These include advocating for harmonized and standardized federal research security policies to reduce administrative burdens and facilitate compliance, the creation of a user-friendly uniform digital CV for disclosures, reasonable approaches to encourage self-disclosure rather than punitive action for unintentional violations, and clarification of institutional responsibilities in certifying researchers’ disclosures. The associations caution against adopting industry-based security standards that may not suit the academic research environment and stress the importance of distinguishing between different types of conflicts (interest versus commitment). They also request greater stakeholder engagement in shaping policies—specifically with the Department of Education regarding Section 117 reporting—and recommend careful consideration of the compliance costs new policies will impose on institutions. In conclusion, the signatories appreciate the OSTP’s engagement with the academic community thus far and encourage ongoing, meaningful consultation to ensure effective, balanced implementation of NSPM-33.
