I want to give all of you an update on where we stand in terms of research security and UGA’s efforts to comply with recent, far-reaching federal policy changes that affect the majority of researchers on campus. I also would like to convey why research security is so important to all of us.
National Security Presidential Memorandum 33 (NSPM-33) is a directive from the president of the United States that requires all federal funding agencies to strengthen their requirements concerning the disclosure of potential conflicts of either interest (one’s personal interests that conflict with those of their employer) and/or commitment (one’s external activities that conflict with their responsibilities to an employer) that could represent a threat to U.S. security.
Since the issuance of NSPM-33 in January 2020, other federal agencies have released related guidance. For example, the Department of Defense (DoD) soon will require all DoD-funded research projects to undergo risk-based security reviews.
Why is this happening? As the memo itself explains, “The American research culture is intentional in its strong commitment to openness. Yet maintaining that open research culture also requires being clear-eyed that certain governments seek to exploit our openness and disrupt the integrity of our research.”
A year ago, I described UGA’s plans to comply with NSPM-33 and how they dovetail with the university’s long-running efforts to improve research security. The memo directs all institutions receiving at least $50 million in federal funding to certify that they have implemented a research security program that covers four aspects:
- Foreign travel security
- Research security training
- Export control training
The good news is that UGA has been building compliance programs in each of these areas for years, even if the programs have not yet been coordinated under the banner of a single research security program. Regarding foreign travel requirements, for example, UGA’s Accounts Payable Travel Policy requires prior approval of an international travel authority, and that travel authority includes registration of international travel with the Office of Global Engagement to provide a centralized record of travel.
Likewise, UGA launched its export control program in 2014 to abide with legislation that regulates the export of goods, software and technology that might be used for purposes harmful to the United States. Reviews for export control compliance are built into multiple Office of Research processes, such as sponsored project submission, requests for material transfer and non-disclosure agreements, international travel registrations, and visiting researcher and scholar questionnaires, and visa sponsorship.
The university has a strategic goal to increase the number of successful funding proposals to U.S. mission agencies such as the U.S. Departments of Energy, Defense, and Homeland Security. In 2022, we created the UGA Research Institute (UGARI) to support that goal. The aims of UGARI are to provide resources to the institution and its researchers to allow us to be better partners for mission agency research. UGARI, for example, is a conduit for the university’s relationship with the Battelle Savannah River Alliance (the five-university alliance of which UGA is a member that, led by Battelle, co-manages the Savannah River National Laboratory).
UGARI deliverables will include the provision of secure research practices that are critical for garnering mission agency funding. Through UGARI, we are contracting with Fischer & Associates, a private firm that specializes in helping universities improve their research security practices, to conduct an assessment of UGA’s capabilities for doing the various types of classified, restricted and controlled unclassified research often involved in mission agency contracts. There can be significant costs in establishing the infrastructure required for such work, and the Fischer assessment will help us chart the best path forward.
We are committed to finalizing and establishing a user-friendly research security program, and to providing the required certification to the federal government in order to continue efforts toward our research goals.
Some of the content covered by NSPM-33 is familiar to UGA, while some is brand new to all research universities. Indeed, this summer the National Science Foundation announced a “Research on Research Security Program” to help U.S. policy makers and investigators understand the nature and scope of this field, including the four critical areas listed above.
The requirements of NSPM-33 will mean additional effort, both by research administrators and by investigators. Please know we will make every effort to streamline the process and allow you to maintain focus on your research and creative works. These regulations would not be in place if the work we do were not so critically important to our nation and world.
I look forward to working with you to develop a research security program that accommodates your needs, while safeguarding the interests of the U.S. research enterprise.
Karen J.L. Burg
Vice President for Research
Harbor Lights Chair in Biomedical Research