NSPM-33

NSPM-33 was signed January 14, 2021, in the final week of the first Trump administration, directing the White House Office of Science and Technology Policy (OSTP) to lead a government-wide effort to align research-security policy across federal research-funding agencies. Implementation continued under the following administration: OSTP, through the National Science and Technology Council (NSTC), issued formal NSPM-33 Implementation Guidance in January 2022 — the document agencies actually build their disclosure rules from.

What the Implementation Guidance requires

The guidance sorts affected researchers into two disclosure tiers. Tier I covered individuals — principal investigators, co-PIs, and other senior/key personnel — must disclose all professional positions and appointments (domestic and foreign, paid or unpaid) and all resources supporting their research (financial or in-kind, domestic or foreign), including foreign talent recruitment program participation, regardless of the level of effort or compensation involved. This is implemented through each agency’s Biographical Sketch and Current and Pending Support forms. Tier II covered individuals — peer reviewers and advisory committee or panel members — face a narrower, conflict-of-interest-focused disclosure obligation tied to the specific applications or portfolios they review.

Agencies were also directed to require a standardised research security program at institutions receiving more than $50 million a year in federal research funding, covering cybersecurity, foreign travel security, insider-threat awareness, and export control training; see the four required program elements for the detail. NSF, NIH, DOE, NASA, USDA, and DOD have each rolled the Common Form and training requirements into agency-specific policy on staggered timelines — NSF adopted the SciENcv-based Common Form for proposals due on or after January 30, 2023, while NIH’s equivalent mandate did not take effect until applications with due dates on or after January 25, 2026.

NSPM-33 itself is a presidential policy directive, not a statute, and creates no penalties on its own; its consequences flow through each agency’s grant terms and, for a narrower set of conduct, through the CHIPS and Science Act, which independently codified the malign foreign talent recruitment program certification and training requirements NSPM-33 also calls for. See Research security policy for how institutions build these disclosure obligations into a working compliance program, and Covered Individual under NSPM-33 for exactly who the Tier I/II categories apply to.