University of North Texas 
Research Security
The University of North Texas Research Security Program is designed to meet the requirements
of NSPM-33.
What is NSPM-33?
The National Science and Technology Council of the Office of Science and Technology
Policy (OSTP) released the GUIDANCE FOR IMPLEMENTING NATIONAL SECURITY PRESIDENTIAL MEMORANDUM 33 (NSPM-33) ON
NATIONAL SECURITY STRATEGY FOR UNITED STATES GOVERNMENT-SUPPORTED RESEARCH AND DEVELOPMENT on Jan. 4, 2022. This memorandum charged OSTP with “coordinating activities to protect
Federally funded R&D from foreign government interference, and outreach to the United
States scientific and academic communities to enhance awareness of risks to research
security and Federal Government actions to address these risks.”
NSPM-33 requires all federal research funding agencies to strengthen and standardize disclosure requirements for federally funded awards. NSPM-33 also mandates the establishment of research security programs at research institutions receiving federal funds.
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.
What are the goals of NSPM-33?
- To protect national security while promoting openness in the research community.
- To make regulations clear so that well-intentioned researchers can easily and properly comply.
- To protect U.S. research integrity by standardizing requirements for universities.
NSPM-33 Requirements
NSPM-33 requires a certification from research organizations awarded more than $50 million per year in total Federal research funding, that they have implemented a research security program that includes these four elements:
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Cybersecurity – When a research project involves Controlled Unclassified Information (CUI), additional steps are taken to safeguard the information. Research Commercial Agreements works closely with the Principal Investigator, the Research Security and Export Control Officer, and UNT System IT to set up Technology Control Plans and System Security Plans. The Cyber Security Maturity Model Certification (CMMC) launched by the Department of Defense outlines cybersecurity requirements for contractors, including universities like UNT. UNT meets the Level 2: Advanced requirements that include the 110 Practices required by NIST 800-171. Federal sponsored research contracts may include a direct or flow-down Defense Federal Acquisition Regulations (DFARs) clause that brings CMMC into scope.
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Foreign travel security – UNT faculty and staff must register international business travel through Risk Management. Risk Management will inform the Research Security & Export Control Officer of all international travel, so that the device checklist process can be completed by the traveler and a loaner laptop provided, when necessary. The Research Security & Export Control Officer will determine if there are any travel restrictions based on any active sponsored projects and will run a restricted party screening on entities and collaborators involved in the travel. GA-48 is Texas-specific legislation (not part of NSPM-33) that requires pre- and post-travel registration for personal travel to specific countries of concern. Read more about GA-48: https://www.untsystem.edu/offices/compliance/untitled.php
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Research Security training – Per Section 10634 of the "CHIPS and Science Act of 2022," covered individuals (senior/key personnel) listed on the application for a research and development award are required to take Research Security training. To meet the agency requirement, UNT researchers must complete the Research Security Training (Combined) course available on CITI. This training must be completed on an annual basis.
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Export Control training All research personnel involved on an export-controlled project must complete Export Control Training prior to project start. This training can be completed via CITI, the live Export Control Responsible Conduct of Research sessions (available each semester), or a live training conducted by the Research Security & Export Control Officer. Export Control training must be completed annually during the life of the award.
Research Security Training FAQS:
Who must complete the research security training?
Per Section 10634 of the "CHIPS and Science Act of 2022," covered individuals” listed
on the application for a research and development award are required to take the training.
Who is a “covered individual”?
Per the NSPM-33 Implementation Guidance Appendix:Definitions, a covered individual is an individual who (a) contributes in a substantive, meaningful
way to the scientific development or execution of a research and development project
proposed to be carried out with a research and development award from a Federal research
agency; and (b) is designated as a covered individual by the Federal research agency
concerned.
How often must the research security training be taken?
On an annual basis.
Why is UNT implementing the research security training requirement if the agency I
am submitting a proposal to is not yet requiring the training?
In anticipation of all federal agencies requiring research security training at the
time of proposal, UNT is requiring all covered individuals to have completed the training
within the last 12 months at the time of proposal submission.
I completed the NSF Research Security Training via Bridge within the last 12 months.
Do I need to take the CITI version?
No, the completion of the NSF Research Security Training via Bridge within the last
12 months can substitute for the CITI Research Security course.
I completed the CITI RCR series and/or the CITI Export Control course. Can this substitute
for the CITI Research Security course?
No, these courses cover different material, so they cannot serve as a substitute for
the CITI Research Security course.
Does CITI offer SSO (Single Sign On)?
UNT’s current subscription to CITI does not include Single Sign On (SSO), so if an
individual has not used CITI before, they will need to set up a username and password
and then affiliate with UNT in order to gain free access to the courses that UNT is
subscribed to.
Research Security Contact:
Meg Cochran
Research Security & Export Control Officer
Margaret.cochran@unt.edu
Phone: 940.565.4258