In 2021, the federal government released a memorandum (NSPM-33) requiring that all federal agencies create policies to mandate research institutions receiving federal funding in excess of $50 million annually to implement training programs for researchers involved in federally funded research.
Research Security Training
Beginning in 2024, Case Western Reserve University will require research security training that covers the following areas:
- Cybersecurity
- International Travel Security
- Research Security
- Export Control
This training will be required for anyone involved in federally funded research. CWRU is working to implement SpartaLearn, a new learning management system, where this training will ultimately be housed.
While the university awaits final agency rules regarding training, CWRU researchers can complete the training through the Collaborative Institutional Training Initiative (CITI) Program.
- Instructions for new CITI users: Register and add the course.
- Instructions for current CITI users: Add the course.
Once in CITI, you will come across a series of enrollment questions. Follow these instructions:
- Select 'Not at this time' for questions 1, 3, 4, and 6.
- Skip the remaining questions.
- Refer to Question 15 for Research Security Training.
Disclosure Requirements for Federally Funded Research
Included in the NSPM-33 are updated disclosure requirements for key personnel and others involved in federally funded research. Please see our Faculty Disclosure and Reporting Guidance page for general and agency-specific guidance on reporting international and domestic activities.
Disclosures are required to be updated under the following conditions:
- In most applications for federally funded research projects (see individual agency requirements).
- After application review and prior to award of funding (if individual agency requires it).
- Annually for each active, federally funded research project.
- At the close of each federally funded research project.
- In real time, as changes occur to circumstances of those involved in federally funded research.
Specific disclosure requirements may differ depending on the funding agency. It is the responsibility of those required to disclose to adhere to the disclosure requirements.
Common Forms
Over the past several months, the National Science and Technology Council (NSTC) Research Security Subcommittee has worked to develop consistent disclosure requirements for use by senior personnel, as well as to develop proposed common disclosure forms for the Biographical Sketch and Current and Pending (Other) Support sections of an application for federal research and development (R&D) grants or cooperative agreements. The National Science Foundation (NSF) has agreed to serve as steward for these common forms. The forms are linked below.
- Common Form for Biographical Sketch
- Common Form for Current and Pending (Other) Support Information
- Definitions
Malign and Other Foreign Talent Recruitment Programs
A Foreign Talent Recruitment Program is any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.
A Malign Foreign Talent Recruitment Program meets the above criteria, plus:
- at least one problematic feature AND
- affiliation with a foreign country of concern, an entity based in a foreign country of concern, or an academic institution or foreign talent recruitment program identified by the Department of Defense.
View a breakdown of what constitutes a malign foreign talent recruitment program.
Participation in a Malign Foreign Talent Recruitment Program by any CWRU employee or researcher is prohibited.
International Travel
CWRU recognizes that international travel is important in the development of collaborative relationships that promote the dissemination of fundamental research. However, it is also essential to be aware of and evaluate potential risks when considering international travel. Such risks include the possibility of theft of data from devices, theft of the devices themselves, and otherwise unintentional transmission of data to unintended and unauthorized individuals and/or institutions. For more information, visit the Travel Resources page.
Get in Touch
For questions, contact Johnny Sams at researchsecurity@case.edu.