Friday, January 7, 2022
Recently there have been some high-profile cases in the news and most recently the Dept. of Justice secured a guilty verdict against prominent Harvard chemistry professor Charles Lieber with regards to disclosures of federally funded research dollars in academia.
The White House released guidance for science agencies to use as they implement National Security Presidential Memorandum 33 (NSPM-33), a document that sets minimum requirements for research security policies across the government.
The new guidance document aims to address continued confusion over what information federally funded researchers must disclose to the government pursuant to NSPM-33, and to address concerns about the administrative burdens of disclosure and the potential for unfair enforcement.
Congress mandated that science agencies develop uniform disclosure policies through the National Defense Authorization Act for Fiscal Year 2021.
The attached guidance included a detailed table indicating the kinds of organizational affiliations, monetary support, and “in-kind” support that must be disclosed. The table resembles ones already produced by the National Institutes of Health and the National Science Foundation.
The guidance reiterates that NSPM-33’s disclosure requirements are intended to apply to principal investigators and “other senior/key personnel” on federal grants, as well as agency program officers, researchers at federal labs, peer reviewers, and federal advisory committee members. It also states that students should generally be exempt from making disclosures to science agencies.