Science & Security

COGR Endorses AUECO Comment Letter to BIS on Export Administration Regulations: Crime Controls and Expansion/Update of U.S. Persons Controls - read more...

COGR Endorses AUECO Letter to U.S. Department of State on International Traffic in Arms Regulations: Revisions to Definition and Controls Related to Defense Services - read more...

COGR Joins a Multi-Association Request to DOE's RTES for Full Engagement with the Research Community Prior to Implementation of Risk Matrices - read more...

Updated: Quick Reference Table of Current & Upcoming Federal Research Security Requirements - read more...

COGR Responds to Request for Comments: Biosketch and Current and Pending Support Disclosure Policy - read more...

Overview of OSTP Guidelines for Research Security Programs at Covered Institutions - read more...

Dear Colleague Letter - Controlled Unclassified Information (CUI) Program at the NSF - read more...

Results from COGR’s Survey on Research Institutions’ Experiences with DoD Policy for Risk-Based Security Reviews of Fundamental Research - read more...

COGR Responds to Advance Notice of Proposed Rulemaking - "Provisions Regarding Access to Americans' Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern" - read more...

COGR Joins a Multi-Association Response to the Request for Comments to Docket Number DoD–2023–OS–0063 / Regulatory Identifier Number (RIN) 0790–AL49, “Cybersecurity Maturity Model Certification (CMMC) Program” - read more...

Update Now Available: Quick Reference Table of Current & Upcoming Federal Research Security Requirements - read more...

Update Now Available (V.4): COGR Matrix of Science & Security Laws, Regulations, and Policies - read more...

COGR, EDUCAUSE, and AAU Submit Joint Comment Letter to GSA on Cyber Threat and Incident Reporting & Information Sharing (FAR 2021-017) - read more...

University Association Comments to NIST - read more...

COGR Letter to OEI HHS-OIG - read more...

COGR Comments & Extension Request to Office of Evaluation and Inspections, OIG, HHS on NIH Monetary Donations that Support Research Survey (OEI-03-22-00570) - read more...

COGR Submits Comments to ORI on Public Health Service Policies on Research Misconduct Notice of Proposed Rulemaking - read more...

COGR Submits Joint Association Request for Extension of Comment Period for Oct. 6, 2023, NPRM on PHS Policies on Research Misconduct (88 FR 69583) - read more...

Analysis of NIST Safeguarding International Science Research Security Framework - read more...

Session Materials Available: Workshop on Compliance with Research Security Requirements and the Associated Cost of Compliance Survey - read more...

On September 27, 2023, COGR is hosted a virtual, interactive workshop to provide an opportunity for members to share information on institutional efforts to comply with research security requirements and how to assess associated costs and institutional burden.  The workshop was led by COGR directors and members of COGR’s four committees.

NSTC is expected to finalize its model disclosure forms and research security program standards this autumn, and upon their issuance, COGR will initiate Phase II of its research security cost survey.  This workshop provided a forum for institutions to discuss their compliance strategies, learn about the methodology of the Phase II survey, and consider the resources they will need to implement research security programs and additional disclosure requirements.  The workshop begins with an overview of current requirements and the Phase II survey, and then participants joined break-out rooms to discuss how their institutions are addressing certification mandates, training requirements, security program structures and associated costs and administrative burden. 

Institutions that participated in the Workshop will be highly encouraged to complete the Phase II Survey.  Phase II will be initiated later this autumn, and COGR will follow-up with workshop participants at the time to determine if they will participate.  

Questions and topics of interest may be sent in advance of the session to Kristin West at kwest@cogr.edu.

Workshop materials include:

Session recording (log in required)
Slide Presentation
Institutional Resources on Research Security (log in required)

COGR, APLU, and AAU Submit Joint Response to Request for Public Comment on Common Disclosure Forms for the Biographical Sketch and Current and Pending (Other) Support for Use in Submission of Research Applications - read more...

Times Up for TikTok Webinar Materials (Slides & Recording) - read more...

At the beginning of this year, the government issued OMB Memorandum M–23–13 banning TikTok on Government Devices.  More recently, DOD, GSA, and NASA issued an interim rule amending the FAR to prohibit ByteDance Covered Application on any information technology owned or managed by the Government or on any information technology used or provided by the contractor under a contract as FAR 52.204-27.  Citing the prohibition on having or using a covered application on information technology, including certain equipment used by Federal contractors, is a national security measure to protect Government information and information and communication technology systems. This webinar provides essential information about the implications of the various federal and state requirements banning Tik Tok and ByteDance Apps for research administrators.  

Speakers for this webinar include William Ferreira, Partner, Hogan Lovells; Mary Ann Blair, Associate Vice President, Chief Information Security Officer, Carnegie Mellon University; Jennifer Rodis, Policy & Planning Analyst, Research and Sponsored Programs, University of Wisconsin-Madison; and Vivian Holmes, Executive Director, Research Administration Services, Massachusetts Institute of Technology. Hosted on September 6, 2023, at 2 p.m. [ET]. 

Questions on this topic may be sent to Krystal Toups at ktoups@cogr.edu.

COGR Supports EDUCAUSE Response to FAR: Prohibition on a ByteDance Covered Application - read more...

COGR Analysis on Executive Order 14104 “Federal Research and Development in Support of Domestic Manufacturing and U.S. Jobs” - read more...

Overview of Department of Defense Statement on Countering Unwanted Foreign Influence in Department-Funded Research Institutions of Higher Education - read more...

COGR Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603) - read more...

Key Results from COGR's Survey Data in Preparation for the NSF Listening Session on the U.S. RSI-ISAO (COGR Portal Log in Required) - read more...

COGR Responds to NSF's Request for Response to Dear Colleague Letter: Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization - read more...

COGR Supports EDUCAUSE Response to NIST's Cybersecurity for R&D Request for Comment - read more...

COGR Responds to OSTP Request for Information: NSPM 33 Research Security Programs Standard Requirement (88 FR 14187) - read more...

COGR Submits Joint Association Request to OSTP for Listening Sessions on Research Security Programs Standards - read more...

COGR Signs on to Multi-Association Letter to DoEd Regarding Foreign Gift & Contract Disclosures (ED-2022-SCC-0159) - read more...

Research Security and the Cost of Compliance – Phase I Report, Disclosure Requirements Now Available - read more...

COGR conducted Phase I of the survey described in this report to quantify the considerable time and resources (financial and otherwise) that research institutions have invested (or will invest) to achieve compliance with the Disclosure Requirements.  COGR is providing this Phase I report to research institutions and federal research funding agencies in the hope that it will both encourage and facilitate discussions of equitable cost allocation, as well as how “return on investment” (ROI) should be considered and measured.

Joint Comments from AAU, AAMC, APLU, ACE and COGR to NSF on Standard Disclosures - read more...

COGR Letter for Request for Comment for Common Disclosure Forms - read more...

NSPM-33 Implementation Guidance Disclosure Requirements Standardization Talking Points for Institutions - read more...

The proposed Standardized Disclosure Forms were released for public comment on August 31, 2022. This document includes critical themes for institutions to consider. These themes were included in the COGR response. 

Overview of the NSPM-33 Standardization Disclosure Forms for the Common Biographical Sketch and Current and Pending (Other) Support 9/23 Webinar Materials - read more...

The highly anticipated Standardize Disclosure Forms were released on August 31, 2022 for public comment. Section 4(b)(vi) of NSPM-33 directs that “agencies should standardize forms for initial disclosures as well as annual updates…and should provide clear instructions to accompany these forms and to minimize any associated administrative burden”. This webinar provides an overview of the standardized disclosure forms and associated attributes highlighting key considerations for institutions.

Speakers for this webinar are Pamela Webb, Associate Vice President for Research, University of Minnesota; Jeffrey Friedland, Associate Vice President, Research Administration; University of Delaware; Craig Reynolds Assistant Vice President for Research - Sponsored Projects University of Michigan; and Krystal Toups, Director, Contracts & Grants Administration. This webinar provides information on how institutions can engage and provide comments by October 31, 2022. 

COGR Matrix of Laws, Regulations, and Policies Regarding Science & Security - read more...

COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security.  The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy (e.g., National Presidential Security Memorandum 33, CHIPS and Science Act of 2022); (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies.  The chart will be updated as new laws, policy and guidance are published. 

COGR Comparison of the Department of Energy Interim Financial Conflict of Interest Policy and Public Health Service Regulations for Promoting Objectivity in Research - read more...

COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security.  The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy (e.g., National Presidential Security Memorandum 33, CHIPS and Science Act of 2022); (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies.  

COGR's Science & Security Resource Page - read more...

The United States government’s focus on inappropriate foreign influence on federally funded research has resulted in an evolving legislative and regulatory environment that research institutions rank as a top compliance concern. Under the leadership of the Office of Science and Technology Policy, federal research funding agencies have/will issue researcher disclosure and research security program requirements in compliance with National Security Presidential Memorandum 33 and legislative requirements, including the FY 2021 National Defense Authorization Acts and the recent CHIPS and Science Act. COGR has developed this Science and Security webpage to provide resources and analysis to assist institutions in navigating requirements in this area. Resources are grouped under the subject-matter headings below, and the page will be updated as existing requirements are clarified and new mandates emerge.

Science & Security Resource Page - read more...

Multi-Association Follow Up Letter to DoEd on Section 117 - read more...

This letter provides comments from the American Council on Education, Association of American Universities, Association of Public and Land-grant Universities, and COGR expressing concerns regarding Dept. of Education requirements under Sec. 117 of the Higher Education Act of 1965. 

Looking at the CHIPS on the Table Webinar Materials - read more...

The CHIPS and Science Act of 2022 is expected to have a major impact on numerous facets of the U.S. science and technology landscape, including manufacturing, support of innovation, STEM education, promotion of more inclusive and diverse research and research settings, along with additional efforts aimed at increasing research security. This COGR webinar provides members which an early look at the new Act, with a particular focus on the new research security provisions, agency authorizations and potential new STEM training and research opportunities.    

Presentation Slides

Recording (Log in required)

Comparison Chart: NIH Pre-Award and Post-Award Disclosures Relating to the Biographical Sketch and Other Support - read more...

This document compares the June 2022 version of the NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support with the prior version of the chart related by NIH.

COGR Submits Comment Letter to OSTP Concerning January 2022 Guidance for Implementing NSPM-33 - read more...

This letter contains COGR’s comments regarding the Implementation Guidance for National Security Presidential Memorandum 33, and stresses the need for transparency, a risk-based approach, and cross-agency consistency. 

Overview of DARPA’s Countering Foreign Influence Program (CFIP) and Senior/Key Personnel Foreign Influence Risk Rubric - read more...

Overview of DARPA’s Countering Foreign Influence Program (CFIP) and Senior/Key Personnel Foreign Influence Risk Rubric DARPA officials Wes Bennett, Director, Contracts Management Office and Kevin Flaherty, Assist. Director, Policy & Oversight, Security & Intelligence Directorate will provide an overview of DARPA’s CFIP. Their presentation will include a discussion of DARPA’s recently revised risk rubric and how the rubric will be used in the grant process. The presentation will include time for questions and answers. 

Presentation Slides

NSPM Presentation Slides - read more...

These are slides from COGR's webinar providing an overview of OSTP's NSPM-33 Implementation Guidance. 

COGR Webinar: Overview of the National Science & Technology Council’s January 4, 2021 Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33)

January 11 @ 4pm ET:  Overview of the National Science & Technology Council’s January 4, 2021 Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33) This webinar will present an overview of the guidance document’s main provisions and discuss key points that institutions should consider.  Plenty of time will be afforded for an audience question and answer period, and questions may be sent to COGR in advance of the webinar. Speakers for this webinar will be: Theresa Colecchia, Senior Associate General Counsel, Johns Hopkins University;  Michael Vernick, Partner Akin Gump Strauss Hauer & Feld LLP; and Kris West, Director, Research Ethics & Compliance, COGR. 

Presentation Slides

Recording (Log in required)

Summary of NSTC Guidance for Implementing National Security Presidential Memorandum 33: Provisions Regarding DPIs, Consequences, Information Sharing and Research Security Programs - read more...

This summary highlights key points of the NSPM-33 Guidance that address the other topics covered by the document: DPIs, consequences, information sharing, and research security programs.

COGR Releases a Summary of NSTC Guidance for Implementing NSPM-33's Disclosure Requirements & Other Provisions - read more...

This summary highlights key points of the NSPM-33 Guidance’s disclosure requirements, including comparison of those provisions with current NIH and NSF requirements in this area. 

Framework for Review of Individual Global Engagements in Academic Research - read more...

This paper provides research institutions with an underlying structure to support the analysis of international engagements by their researchers, assess potential risks, and develop strategies for mitigation.

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COGR Submits Letter to OSTP on Reducing Administrative Burden - read more...

This letter provides specific suggestions to OSTP for achieving its objective of reducing administrative burden associated with federally funded research, including suggestions regarding research security requirements.  

Posted December 21, 2021

COGR Submits Comment Letter to NSF in Response to "Notice of a New System of Records: (SORN) - read more...

This letter provides comments regarding to NSF concerning its Privacy Act notice of a new system of records that describes the use of a data analytics tool to analyze information collected from researcher disclosures. 

Posted December 8, 2021

Principles for Evaluating Conflict of Commitment Concerns in Academic Research (Update) - read more...

Updated September 22, 2021

This paper examines the issue of conflict of commitment in the context of concerns regarding inappropriate foreign influence, promoting transparency, and avoiding conflicts. 

Federal Focus on Inappropriate Foreign Influence on Research: Practical Considerations in Developing an Institutional Response - read more...

This paper provides an overview of points that institutions should consider on issues related to research security as they perform risk assessments and develop/implement processes to appropriately address areas of higher research security risk

COGR, AAU, and APLU Submit Letter to DOE on Order 142.3B - read more...

Posted July 12, 2021

This letter sets forth comments to the Dept. of Energy from COGR, Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU) regarding the application of DOE Order 142.3B and the removal of the  limited screening exemption for U.S. universities

Joint Association Comments on NIST NPRM Proposed Changes to Part 401 and 404 - read more...

Posted April 5, 2021

This letter provides association comments regarding changes proposed to Part 401 Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants Contracts and Cooperative Agreements.

COGR’s Survey on Institutional Disclosure Practices: Responding to Inappropriate Foreign Influence Amid Evolving Requirements

COGR’s Survey on Institutional Disclosure Practices: Responding to Inappropriate Foreign Influence Amid Evolving Requirements (Log in required)

Released December 2020

This paper provides analysis of the data collected via COGR's survey on institutional disclosure requirements regarding research support and researcher affiiliations.  It is availble only to COGR members. 

Joint Association Comment Letter Regarding Foundational Technologies ANPRM - read more...

Posted November 2020

This letter contains joint association comments regarding concerns associated with potential expansion of controls on foundational technologies. 

Conflict of Commitment Policies for COGR Member Institutions - read more...

Posted November 19, 2019

COGR's Response to JCORE RFI - read more...

Posted January 27, 2020

This letter contains COGR's comments in response to the request for information on aspects of the American Research Environment [FR Doc. 2019-25604]

ARCHIVED: Foreign Influence Resources Provided by COGR Members (ARCHIVED) - read more...

Posted October 3, 2019

Joint Association Letter to NIST on Protecting Controlled Unclassified Information SP800-171B - read more...

Posted August 2, 2019

This letter sets forth joint association comments expressing questions and concerns about how sponsoring agencies will apply the enhanced requirements of NIST SP 800-171B.

Association Response to DoEd on Section 117 Reporting - read more...

Posted 7/12/19

This letter expresses joint association concerns regarding the continuing need for clarification regarding reporting requirements under Sec. 117 of the Higher Education Act of 1965. 

Joint Association Comment Letter on Emerging Technologies ANPRM - read more...

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This letter contains joint association comments in response to the Advance Notice of Proposed Rulemaking Regarding Review of Controls for Certain Emerging Technologies Reference: 83 Fed. Reg. 58201 (Nov. 19, 2018).

Joint Association Memo Requesting Extension from BIS - read more...

Posted December 4, 2018

This letter contains a joint association request for an extension to provide comments in response to the Advance Notice of Proposed Rulemaking (ANPRM) on the “Review of Controls for Certain Emerging Technologies published by the Bureau of Industry and Security (BIS) in the Federal Register on November 19, 2018.

Final Joint Association Comments on Proposed Changes to the NIH Guidelines on Recombinant or Synthetic Nucleic Acid Research - read more...

Posted October 10, 2018

COGR Submits Letter to DOD on Security Requirements - read more...

Posted 5/29/18

This letter contains COGR's comments seeking DOD clarification that SSPs and NIST compliance is not required in contracts or subcontracts involving solely the performance of fundamental research, and/or research not involving any covered defense information or other types of controlled unclassified information.

COGR Submits Joint Association Letter on DOE Regulatory Reform - read more...

Posted July 14, 2017

This letter provides joint association comments on Department of Energy regulations, paperwork requirements and other regulatory obligations as part of the agency’s implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.” 

Letter from National Security Advisor to CSIS

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This is a copy of a letter from Dr. Rice, National Security Advisor to the President in response to a letter from COGR on the Future of Technology and Public Policy regarding export controls and fundamental research.

Copy of NSDD 189

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Text of NSDD 189 re. fundamental research. 

Troublesome Clauses

COGR and MIT jointly are maintaining a list of government contract clauses reported to us by universities that contain restrictions on publications and participation of foreign nationals.
Click here to view the list