Georgia Tech is committed to maintaining an open environment to foster research discoveries and innovation that benefit our community and the world. Our international partnerships play a crucial role in our mission, and we are proud to connect students, faculty, and research collaborators around the world.
While an open, collaborative environment is supported at Georgia Tech, we must also project your research and development against foreign government interference and misappropriation. Several federal mandates, including the implementation of National Security Presidential Memorandum-33, are informing ongoing changes in Institute systems, policies, and procedures.
If you are a Georgia Tech employee working directly on U.S. federally funded sponsored research projects and travel internationally, the following important updates apply to you.
- Why is protecting your research important?
- Learn more about foreign influence
- NSPM-33 what is it and how does it impact you?
- ORCID ID – setting it up & connecting it to Georgia Tech
- Updated foreign travel requirements – if you are traveling to certain countries, you will be required to complete a foreign travel notification to Research Security 30 days prior to your departure
- Changes to disclosures
Why is protecting your research important?
There is an increasing need to protect U.S. federally funded scientific research from undue foreign influence, including exploitation of the open university research environment and intellectual property theft. Federal initiatives around research compliance including NSPM-33, the CHIPS (Creating Helpful Incentives to Produce Semiconductors) and Science Act, and CMMC (Cybersecurity Maturity Model Certification) are working to address this need.
Research is led by principal investigators (PIs). Their ideas engage students and other researchers, and the PIs secure grants to help fund and support their research. Collaborations can also be established with institutions outside of Georgia Tech and the United States.
The centrality of PIs to the research enterprise places them most at risk of foreign interference or influence as well as U.S. government investigation, and their role in risk assessment and management is central.
PIs are responsible for continuously ensuring that all members of their research groups understand the norms and expectations regarding the sharing of information outside the group.
To support researchers in this work, Georgia Tech aims to:
- Maintain an open environment to foster research discoveries and innovation while providing guidelines for protecting your research
- Provide the information needed for compliance
- Minimize risks
What is foreign influence?
The U.S. Government, including members of Congress and federal agencies, has expressed serious concerns regarding inappropriate influence by foreign entities, government, or individuals on U.S. institutions and researchers. Concerns of foreign influence are:
- Inappropriate or inadvertent sharing of proprietary information, intellectual property, or data of grant applications, unpublished research, or technologies.
- Sharing of confidential information by researchers serving as peer reviewers of grant applications.
- Failure of researchers to disclose substantial support from outside activities or foreign organizations in grant application Current & Pending forms. There are concerns regarding the failure to follow federal agency requirements to disclose foreign components or foreign collaborations in progress reports or ongoing awards.
Several federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding.
The Office of Science and Technology Policy (OSTP) issued guidance regarding government-wide foreign interest and activity disclosure requirements in accordance with National Security Presidential Memorandum (NSPM-33): Presidential Memorandum on United States Government-Supported Research and National Security.
NSPM-33: What is it and how does it impact you?
The Presidential Memorandum on United States Government-Supported Research and Development National Security Policy, more commonly known as National Security Presidential Memorandum 33 (NSPM-33), was released at the end of the last presidential administration. A year later, the National Science and Technology Council issued guidance for NSPM-33’s implementation. This guidance includes several mandatory federal requirements designed to enhance the protections of U.S. Government-supported research and development (R&D) against foreign government interference and misappropriations by maintaining an open environment fostering research discoveries and innovation that benefit the United States and the world. These mandatory requirements will provide consistency while preserving the open and collaborative nature of the U.S. research enterprise through enhanced research security techniques focused on responsibilities, transparency, and equity.
NSPM-33 requires all federal research funding agencies to strengthen and standardize disclosure requirements for federally funded awards. NSPM-33 mandates the establishment of research security programs at research institutions receiving federal funds. NSPM-33 will also require oversight and enforcement activity in the form of administrative actions as well as civil or criminal penalties.
Why is NSPM-33 required?
There is an increasing need to protect U.S. funded scientific research from undue foreign influence, including exploitation of the open university research environment and intellectual property theft. NSPM-33 applies to research organizations awarded more than $50 million per year in total federal research funding.
What are the goals of NSPM-33?
- To protect America’s national security while promoting openness in the research community
- To ensure that policies do not fuel xenophobia or prejudice
Georgia Tech has established a working group to address the key NSPM-33 areas.
The working group's objective is to customize solutions for the Georgia Tech environment that will protect the researcher, without increasing bureaucracy. Four subgroups focus on different compliance requirements:
- Disclosure Requirements, Standardization and Consequences for Violation – many disclosure requirements are being standardized across government agencies; therefore, the Georgia Tech working group is evaluating agency guidance as it evolves.
- Digital Persistent Identifiers – registration for an ORCID iD has been identified as the solution for this requirement. All Georgia Tech researchers are recommended to register and obtain an ORCID iD and connect it to Georgia Tech.
- Research Security Program: Foreign Travel Security, Research Security Training and Export Control Training – Georgia Tech’s working group has been working closely with GTRI to design processes and training for the Georgia Tech federally funded researcher. This includes the following areas: foreign travel security, research security export control, insider threat awareness, cybersecurity, etc.
- Research Security Program :Cybersecurity
For Georgia Tech researchers, one easy step toward compliance with NSPM-33 is registering with ORCID to receive a digital identifier (an ORCID iD).
ORCID is a non-profit organization supported by a global community of member organizations, including research institutions, publishers, funders, professional associations, service providers, and other stakeholders in the research ecosystem.
You can access ORCID training videos by logging into Georgia Tech's Learning Management System using SSO, then search using the word "ORCID" or under the "How To" category.
Updated Foreign Travel Requirements
All Georgia Tech employees working directly on U.S. federally funded sponsored research projects and traveling overseas on official business will continue to follow Georgia Tech policy by completing the WorkDay Spend Authorization.
When completing the WorkDay Spend Authorization, the traveler answers a series of questions.
NEW QUESTION on Form: asks if you are traveling to either an Office of Foreign Assets Control (OFAC) embargoed country:or countries identified in 22 CFR 126.1(d)(1) & (d)(2) Tables 1 & 2.
- If the answer is NO, no further action is required.
- If the answer is YES, you will be required to complete a foreign travel notification to Research Security (RS) 30 days prior to your departure.
Upon completion of the RS notification, a RS member will provide a valuable safety and security briefing prior to your departure.
This information will be documented and retained for future self-reviews by the Institute and inspections by the U.S. Government.
NOTE: All Georgia Tech personnel who have a security clearance are required to report ALL work and personal foreign travel regardless of country.
Personal Foreign Travel – Georgia Tech personnel who do not possess a clearance and are using personal funds for travel (i.e. vacation) are not required – but are highly encouraged – to report foreign travel to assist in travel safety, emergency evacuation or other State Department assistance programs. This form can be completed for reporting.
If you have questions or need clarification on the requirements, please email email@example.com.
Changes to DisclosuresResearchers submitting proposals to federal sponsors will need to certify the accuracy and completeness of the below information:
- Other Support
- Current and Pending
- Keeping your information updated in SciENcv assists you in complying with this requirement.
Learn how to create an NSF-approved biosketch with SCiENcv.