The NSTC Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33) Disclosure Requirements, Version 2.0 (January 11, 2022), outlines uniform protocols and standards for disclosure requirements mandated for U.S. Government-supported research and development activities. The guidance acts as a foundational step toward harmonizing disclosure policies across federal research agencies, aiming to enhance national security while minimizing administrative burden on researchers and institutions. It directs agencies to utilize standardized forms and definitions, integrate specific statutory requirements, consult with stakeholders during implementation, and apply requirements non-discriminatorily, with particular caution to not burden undergraduate and graduate students unnecessarily.
The document delineates the definition and scope of required disclosures—including positions, appointments, support (current, pending, and other), foreign government-sponsored talent recruitment program participation, and other relevant activities—while also clarifying exclusions such as routine teaching or internal mentoring. Importantly, the guidance acknowledges variations in agency practice, especially regarding consulting, honoraria, and mentoring, and it compares these with current NIH and NSF policies, highlighting key differences. The document requires both individual and institutional certification of disclosed information, mandates correction procedures for inaccurate submissions, and specifies the handling of foreign contracts and documentation. Overall, the guidance strives for a balanced approach: reinforcing national security interests and the integrity of federally funded research, while ensuring fair, clear, and consistent expectations for researchers and administrators.
