Science & Security

September 23, 2022

Overview of the NSPM-33 Standardization Disclosure Forms for the Common Biographical Sketch and Current and Pending (Other) Support 9/23 Webinar Materials - read more...

The highly anticipated Standardize Disclosure Forms were released on August 31, 2022 for public comment. Section 4(b)(vi) of NSPM-33 directs that “agencies should standardize forms for initial disclosures as well as annual updates…and should provide clear instructions to accompany these forms and to minimize any associated administrative burden”. This webinar provides an overview of the standardized disclosure forms and associated attributes highlighting key considerations for institutions.

Speakers for this webinar are Pamela Webb, Associate Vice President for Research, University of Minnesota; Jeffrey Friedland, Associate Vice President, Research Administration; University of Delaware; Craig Reynolds Assistant Vice President for Research - Sponsored Projects University of Michigan; and Krystal Toups, Director, Contracts & Grants Administration. This webinar provides information on how institutions can engage and provide comments by October 31, 2022. 

 

September 7, 2022

COGR Matrix of Laws, Regulations, and Policies Regarding Science & Security - read more...

COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security.  The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy (e.g., National Presidential Security Memorandum 33, CHIPS and Science Act of 2022); (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies.  The chart will be updated as new laws, policy and guidance are published. 

 

September 7, 2022

COGR Comparison of the Department of Energy Interim Financial Conflict of Interest Policy and Public Health Service Regulations for Promoting Objectivity in Research - read more...

COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security.  The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy (e.g., National Presidential Security Memorandum 33, CHIPS and Science Act of 2022); (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies.  

 

September 2, 2022

COGR's Science & Security Resource Page - read more...

The United States government’s focus on inappropriate foreign influence on federally funded research has resulted in an evolving legislative and regulatory environment that research institutions rank as a top compliance concern. Under the leadership of the Office of Science and Technology Policy, federal research funding agencies have/will issue researcher disclosure and research security program requirements in compliance with National Security Presidential Memorandum 33 and legislative requirements, including the FY 2021 National Defense Authorization Acts and the recent CHIPS and Science Act. COGR has developed this Science and Security webpage to provide resources and analysis to assist institutions in navigating requirements in this area. Resources are grouped under the subject-matter headings below, and the page will be updated as existing requirements are clarified and new mandates emerge.

 

August 24, 2022

Science & Security Resource Page - read more...

 

August 16, 2022

Multi-Association Follow Up Letter to DoEd on Section 117 - read more...

This letter provides comments from the American Council on Education, Association of American Universities, Association of Public and Land-grant Universities, and COGR expressing concerns regarding Dept. of Education requirements under Sec. 117 of the Higher Education Act of 1965. 

 

August 11, 2022

Looking at the CHIPS on the Table Webinar Materials - read more...

The CHIPS and Science Act of 2022 is expected to have a major impact on numerous facets of the U.S. science and technology landscape, including manufacturing, support of innovation, STEM education, promotion of more inclusive and diverse research and research settings, along with additional efforts aimed at increasing research security. This COGR webinar provides members which an early look at the new Act, with a particular focus on the new research security provisions, agency authorizations and potential new STEM training and research opportunities.    

Presentation Slides

Recording (Log in required)

 

June 8, 2022

Comparison Chart: NIH Pre-Award and Post-Award Disclosures Relating to the Biographical Sketch and Other Support - read more...

This document compares the June 2022 version of the NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support with the prior version of the chart related by NIH.

 

February 15, 2022

COGR Submits Comment Letter to OSTP Concerning January 2022 Guidance for Implementing NSPM-33 - read more...

This letter contains COGR’s comments regarding the Implementation Guidance for National Security Presidential Memorandum 33, and stresses the need for transparency, a risk-based approach, and cross-agency consistency. 

 

January 19, 2022

Overview of DARPA’s Countering Foreign Influence Program (CFIP) and Senior/Key Personnel Foreign Influence Risk Rubric - read more...

 

Overview of DARPA’s Countering Foreign Influence Program (CFIP) and Senior/Key Personnel Foreign Influence Risk Rubric DARPA officials Wes Bennett, Director, Contracts Management Office and Kevin Flaherty, Assist. Director, Policy & Oversight, Security & Intelligence Directorate will provide an overview of DARPA’s CFIP. Their presentation will include a discussion of DARPA’s recently revised risk rubric and how the rubric will be used in the grant process. The presentation will include time for questions and answers. 

Presentation Slides

 

January 13, 2022

NSPM Presentation Slides - read more...

These are slides from COGR's webinar providing an overview of OSTP's NSPM-33 Implementation Guidance. 

 

January 11, 2022

COGR Webinar: Overview of the National Science & Technology Council’s January 4, 2021 Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33)

January 11 @ 4pm ET:  Overview of the National Science & Technology Council’s January 4, 2021 Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33) This webinar will present an overview of the guidance document’s main provisions and discuss key points that institutions should consider.  Plenty of time will be afforded for an audience question and answer period, and questions may be sent to COGR in advance of the webinar. Speakers for this webinar will be: Theresa Colecchia, Senior Associate General Counsel, Johns Hopkins University;  Michael Vernick, Partner Akin Gump Strauss Hauer & Feld LLP; and Kris West, Director, Research Ethics & Compliance, COGR. 

Presentation Slides

Recording (Log in required)

 

January 10, 2022

Summary of NSTC Guidance for Implementing National Security Presidential Memorandum 33: Provisions Regarding DPIs, Consequences, Information Sharing and Research Security Programs - read more...

This summary highlights key points of the NSPM-33 Guidance that address the other topics covered by the document: DPIs, consequences, information sharing, and research security programs.

 

January 7, 2022

COGR Releases a Summary of NSTC Guidance for Implementing NSPM-33's Disclosure Requirements & Other Provisions - read more...

This summary highlights key points of the NSPM-33 Guidance’s disclosure requirements, including comparison of those provisions with current NIH and NSF requirements in this area. 

 

December 31, 2021

Framework for Review of Individual Global Engagements in Academic Research - read more...

This paper provides research institutions with an underlying structure to support the analysis of international engagements by their researchers, assess potential risks, and develop strategies for mitigation.

Click Here

 

December 21, 2021

COGR Submits Letter to OSTP on Reducing Administrative Burden - read more...

This letter provides specific suggestions to OSTP for achieving its objective of reducing administrative burden associated with federally funded research, including suggestions regarding research security requirements.  

Posted December 21, 2021

 

December 8, 2021

COGR Submits Comment Letter to NSF in Response to "Notice of a New System of Records: (SORN) - read more...

This letter provides comments regarding to NSF concerning its Privacy Act notice of a new system of records that describes the use of a data analytics tool to analyze information collected from researcher disclosures. 

Posted December 8, 2021

 

September 22, 2021

Principles for Evaluating Conflict of Commitment Concerns in Academic Research (Update) - read more...

Updated September 22, 2021

This paper examines the issue of conflict of commitment in the context of concerns regarding inappropriate foreign influence, promoting transparency, and avoiding conflicts. 

 

August 18, 2021

Federal Focus on Inappropriate Foreign Influence on Research: Practical Considerations in Developing an Institutional Response - read more...

This paper provides an overview of points that institutions should consider on issues related to research security as they perform risk assessments and develop/implement processes to appropriately address areas of higher research security risk

 

July 12, 2021

COGR, AAU, and APLU Submit Letter to DOE on Order 142.3B - read more...

Posted July 12, 2021

This letter sets forth comments to the Dept. of Energy from COGR, Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU) regarding the application of DOE Order 142.3B and the removal of the  limited screening exemption for U.S. universities

 

April 5, 2021

Joint Association Comments on NIST NPRM Proposed Changes to Part 401 and 404 - read more...

Posted April 5, 2021

This letter provides association comments regarding changes proposed to Part 401 Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants Contracts and Cooperative Agreements.

 

December 18, 2020

COGR’s Survey on Institutional Disclosure Practices: Responding to Inappropriate Foreign Influence Amid Evolving Requirements

COGR’s Survey on Institutional Disclosure Practices: Responding to Inappropriate Foreign Influence Amid Evolving Requirements (Log in required)

Released December 2020

This paper provides analysis of the data collected via COGR's survey on institutional disclosure requirements regarding research support and researcher affiiliations.  It is availble only to COGR members. 

 

November 5, 2020

Joint Association Comment Letter Regarding Foundational Technologies ANPRM - read more...

Posted November 2020

This letter contains joint association comments regarding concerns associated with potential expansion of controls on foundational technologies. 

 

August 4, 2020

Conflict of Commitment Policies for COGR Member Institutions - read more...

Posted November 19, 2019

 

January 27, 2020

COGR's Response to JCORE RFI - read more...

Posted January 27, 2020

This letter contains COGR's comments in response to the request for information on aspects of the American Research Environment [FR Doc. 2019-25604]

 

August 23, 2019

ARCHIVED: Foreign Influence Resources Provided by COGR Members (ARCHIVED) - read more...

Posted October 3, 2019

 

August 2, 2019

Joint Association Letter to NIST on Protecting Controlled Unclassified Information SP800-171B - read more...

Posted August 2, 2019

This letter sets forth joint association comments expressing questions and concerns about how sponsoring agencies will apply the enhanced requirements of NIST SP 800-171B.

 

July 12, 2019

Association Response to DoEd on Section 117 Reporting - read more...

Posted 7/12/19

This letter expresses joint association concerns regarding the continuing need for clarification regarding reporting requirements under Sec. 117 of the Higher Education Act of 1965. 

 

January 10, 2019

Joint Association Comment Letter on Emerging Technologies ANPRM - read more...

Click here to view

This letter contains joint association comments in response to the Advance Notice of Proposed Rulemaking Regarding Review of Controls for Certain Emerging Technologies Reference: 83 Fed. Reg. 58201 (Nov. 19, 2018).

 

December 4, 2018

Joint Association Memo Requesting Extension from BIS - read more...

Posted December 4, 2018

This letter contains a joint association request for an extension to provide comments in response to the Advance Notice of Proposed Rulemaking (ANPRM) on the “Review of Controls for Certain Emerging Technologies published by the Bureau of Industry and Security (BIS) in the Federal Register on November 19, 2018.

 

October 10, 2018

Final Joint Association Comments on Proposed Changes to the NIH Guidelines on Recombinant or Synthetic Nucleic Acid Research - read more...

Posted October 10, 2018

 

May 29, 2018

COGR Submits Letter to DOD on Security Requirements - read more...

Posted 5/29/18

This letter contains COGR's comments seeking DOD clarification that SSPs and NIST compliance is not required in contracts or subcontracts involving solely the performance of fundamental research, and/or research not involving any covered defense information or other types of controlled unclassified information.

 

July 14, 2017

COGR Submits Joint Association Letter on DOE Regulatory Reform - read more...

Posted July 14, 2017

This letter provides joint association comments on Department of Energy regulations, paperwork requirements and other regulatory obligations as part of the agency’s implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.” 

 

November 1, 2001

Letter from National Security Advisor to CSIS

Click here to view

This is a copy of a letter from Dr. Rice, National Security Advisor to the President in response to a letter from COGR on the Future of Technology and Public Policy regarding export controls and fundamental research.

 

September 21, 1985

Copy of NSDD 189

Click here to view

Text of NSDD 189 re. fundamental research. 

 

Troublesome Clauses

COGR and MIT jointly are maintaining a list of government contract clauses reported to us by universities that contain restrictions on publications and participation of foreign nationals.
Click here to view the list