UMass Amherst supports the maintenance of an open environment to foster research discoveries and innovation. However, it is important that processes are implemented to protect intellectual capital, discourage research misappropriation, and ensure responsible management of United States taxpayer dollars. The information provided below describes steps UMass Amherst has taken to comply with the Presidential Memorandum on United States Government-Supported Research and Development National Security Policy (NSMP-33), the CHIPS and Science Act of 2022 (42 U.S.C. 19232), and other Federal requirements to ensure threats to national security and potential conflicts of interest and conflicts of commitment are identified, disclosed, and mitigated.
Research security training in CITI is available to everyone with an active UMass NetID.
The University of Massachusetts Travel Polic provides an overview of how UMass Amherst complies with the NSPM-33 requirements to maintain an organizational record of international travel, including sponsored international travel, for organization business, teaching, conference attendance, and research purposes when security risks warrant travel reporting.
The Pre-travel Review and Approval Process for International Travel includes an export control review as well as additional planning for personal safety and cybersecurity, particularly when traveling to high risk destinations.
The UMass IT Security Guidance for Domestic and International Travel website can be accessed here.
In compliance with Massachusetts Standards for the Protection of Personal Information of Residents, the University of Massachusetts now requires annual mandatory cybersecurity training for all employees. Please see details on the Cybersecurity Training & Resources for UMass Employees.
Additional training requirements for researchers may become effective in the future based on the NSPM-33 requirements. UMass Amherst will be required to certify that the institution will implement a cybersecurity program consistent with the cybersecurity resource for research institutions described in the CHIPS and Science Act, within one year after the National Institute of Standards and Technology (NIST) of the Department of Commerce publishes that resource.
UMass Amherst requires individuals who perform research activities involving export-controlled technologies to complete training. The goal of the training is to ensure individuals understand how to comply with (1) U.S. export control and compliance requirements; and (2) requirements for review of foreign sponsors, collaborators, and partnerships.
The Export Control Training page provides instructions on how to access the training modules.
Research security training, including basic and more detailed advanced courses, are available through the CITI Program. The Research Security Training webpage provides instructions on how to access the module.
It is the Policy of the University of Massachusetts to comply with NSF, NIH, DoD, DoE and any other agencies’ or federal departments’ MFTRP requirements. Therefore, in accordance with the CHIPS and Science Act of 2022, Section 10632 (42 U.S.C. 19232), individuals who are a party to a malign foreign talent recruitment program (MFTRP) shall not serve as senior/key personnel on Federally funded research. For further details, see th University of Massachusetts Policy Statement on Malign Foreign Government Talent Recruitment Programs.
For reference, see the list of Foreign Institutions engaging in problematic activity as described in Section 1286 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019, updated annually.
The definition of MFTRP can be found at 42 U.S.C. 19237(4)
Additionally, 42 U.S.C. 19232(a)(1) requires that covered individuals submit a certification stating that they are not a party to a MFTRP at the time of submission, annually after proposal submission, and immediately if at any time participation status changes for the duration of the award.
Federal departments and agencies that fund research and development have long been concerned with the potential for foreign entities, both private companies and government institutions, to inappropriately interfere with U.S. Government-supported research. To address this, many institutions of higher education, including UMass, encourage a robust disclosure of international research collaborations.
Any researchers involved in international collaborations should disclose collaborations in advance in their annual Kuali Conflict of Interest Disclosure, which includes specific questions about foreign engagements. Following this disclosure, staff from the Office of Research Compliance will review the anticipated international activities for the potential application of export control regulations or other state or Federal regulations or requirements and provide guidance as necessary.
The following contacts are available to respond to specific questions that researchers involved in international collaborations may have. If you are unclear on the best approach, please contact the Office of Research Compliance at (413) 545-5283 or @email.
| Office | Key Point of Contact | Confer in case of: |
|---|---|---|
| Office of Pre-Award Services (OPAS) | Kristy Reese, Director (413) 545-0699 |
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| Office of Post-Award Management (OPAM) |
Alene Denson, Director |
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| Office of Research Compliance (ORC) |
Heather Hermann, Director of Research Security & Risk Management |
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| Technology Transfer Office (TTO) |
Burnley Jaklevic, Director |
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| International Programs Office |
Andrea Campbell Drake, Director of Health Safety and Security |
|
| International Scholars & Students |
Kenneth Reade, Director, International Student and Scholar Services |
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| IT Security & Compliance |
Jacob Cunningham, Chief Information Security Officer |
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| Office of Research Compliance (ORC), Research Risk, Foreign Engagement |
Ellie Kurth, Assistant Director of Research Risk |
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| Foundation |
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Any researchers planning to become involved in foreign engagements should disclose them in advance, on their UMass Amherst Kuali Conflict of Interest Disclosure, which includes specific questions about foreign engagements.
If you have academic, professional, or institutional appointments or positions with a foreign government or government-connected entity, whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary), where direct monetary or non-monetary reward is involved, these should be disclosed.
Additionally, academic, professional, or institutional appointments or positions with a foreign government or government-connected entity, whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary), where no direct monetary or non-monetary reward is involved must also be disclosed.
Individuals should be prepared to provide information about the foreign entity, as well as copies of any written agreements or contracts entered into with the foreign entity.
Finally, information about visiting scholars should also be disclosed, including the name of the home institution, their visit dates, and sources of funding.
Pre-award and post-award disclosure requirements can be found at “NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support”.
DARPA
- Require disclosure of Current and Pending Support to align with NSMP-33 and NDAA for Fiscal Year 2021 (adopted DoD Memo Countering Unwanted Foreign Influence in Department-Funded Research at IHEs June 29, 2023).
- Disclosure Table
- Requires Research Security Training
- Prohibits senior/key personnel from participating in a MFTRP.
- Utilizes DoD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions.
- Guidance provided at the DoD Academic Research Security webpage
DEVCOM ARL (Army Research Lab)
- Require disclosure of Current and Pending Support to align with NSMP-33 and NDAA for Fiscal Year 2021.
- Disclosure Table
- Requires Research Security Training
- Prohibits senior/key personnel from participating in a MFTRP.
- Utilizes the AFC Army Research Risk Assessment Protection Program (ARRP) Risk Matrix to evaluate proposals
- Considers active or past affiliations with Strategic Competitors when evaluating risk.
DoD
- Require disclosure of Current and Pending Support to align with NSMP-33 and NDAA for Fiscal Year 2021 requirements (DoD Memo OUSD March 20, 2019 and DoD Memo Countering Unwanted Foreign Influence in Department-Funded Research at IHEs June 29, 2023).
- Disclosure Table
- Requires Research Security Training
- Prohibits senior/key personnel from participating in a MFTRP.
- Utilizes DoD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions.
- Guidance provided at the DoD Academic Research Security webpage
DOE and National Nuclear Security Administration (NNSA)
- Require disclosure in Current and Pending Support to align with NSMP-33 and NDAA for Fiscal Year 2021 requirements (FAL No. 2022-04) and allow use of SciENcv to provide information.
- Disclosure Table
- Require use of persistent digital identifiers (PIDs) (FAL 2024-05)
- Requires Research Security Training
- Requires senior/key personnel to certify annually that they are not a party to a MFTRP.
- Prohibits participation in Foreign Government-Sponsored Talent Recruitment Programs (DOE O 486.1A)
- Notification to DOE within 5 business days upon learning that an individual on the project team is or is believed to be participating in a malign foreign talent recruitment program.
- Utilizes Framework for Assessing Research, Technology, and Economic Security (RTES) Risk to evaluate disclosures.
EPA
- Issued a Management Implication Report: Disclosure of Foreign Support for EPA Research Grants 4/13/23. Anticipate EPA will comply with disclosures of foreign support requirement soon.
- Requires Research Security Training
- Anticipate EPA will comply with the NSMP-33 and NDAA for Fiscal Year 2021and require senior/key personnel to certify annually that they are not a party to a MFTRP.
NASA
- Adopted Common Disclosure Forms as of October 2024
- Disclosure Table
- Requires Research Security Training
- Requires senior/key personnel to certify annually that they are not a party to a MFTRP.
- Requires assurance and representation on China restrictions. Proposer assurance that they are not a China or a Chinese-owned company, and that the proposer will not participate, collaborate, or coordinate bilaterally with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement. (Section 1340 of Public Law 112-10 and Section 539 of Public Law 112-55).
NIST
- Adopted Common Disclosure Forms
- Disclosure Table
- Requires Research Security Training
- Requires senior/key personnel to certify annually that they are not a party to a MFTRP.
NIH
- Notice to adopt Common Disclosure Forms as of May 25, 2025 has been postponed.
- Disclosure Table
- Requires Research Security Training
- Requires senior/key personnel to certify annually that they are not a party to a MFTRP.
- Uses the NIH Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senoir/Key Personnel.
NSF
- Adopted Common Disclosure Forms as of November 1, 2023.
- Disclosure Table
- Requires Research Security Training
- Requires senior/key personnel to certify annually that they are not a party to a MFTRP.
- Uses the Trusted Research Using Safeguards and Transparency (TRUST) framework to assess grant proposals for potential national security risks.
SciENcv is a researcher profile system for all individuals who apply for, receive, or are associated with research investments from federal agencies.
You will be required to use SciENcv to complete Common Forms (i.e., Biographical Sketch, Current and Pending (Other) Support) to produce digitally certified PDF(s) for use in application submission for some federal agencies.
ORCID is a free, unique, persistent identifier (PID) for individuals to use as they engage in research, scholarship, and innovation activities.
You will be required to enter your ORCID ID in the Persistent Identifier (PID) section of the Common Forms.
If it is determined that a senior/key person failed to disclose required information, federal agencies may take one or more of the following actions:
- Reject a proposal;
- Suspend or terminate an award;
- Temporarily or permanently discontinue any or all funding for the individual or entity;
- Preserve an award, but require or otherwise ensure that a senior/key person does not perform work under the award;
- Suspend or debar recipients as appropriate and consistent with 2 CFR part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement) as adopted by Federal Agencies.
- Refer the failure to disclose to the Agency Office of Inspector General for further investigation or to Federal law enforcement authorities to determine whether any criminal or civil laws were violated;
- Report the individual or entity in SAM.gov to alert other Federal agencies to the noncompliance;
- Take one or more of the actions described in 2 CFR 200.339, Remedies for noncompliance; or
- Take such other actions against the senior/key person or entity as authorized under applicable law or regulations.
- Department of Defense (DOD) — Academic Research Security (Office of the Under Secretary of Defense for Research & Engineering): This site is a resource for the actions that the Department and the inter-agency are taking to ensure the integrity of fundamental research in academia as well as steps that the academic community has taken.
- Department of Defense (DOD) Research and Engineering: Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education. Memorandum on the policy for Risk-Based Security Reviews of Fundamental Research mandated by section 1286 of the National Defense Authorization Act for FY 2019 and NSPM-33.
- Department of Energy (DOE)— DOE Current and Pending Support Disclosure Requirements for Financial Assistance (FAL 2022-04): response to NSPM-33.
- Director of National Security (ODNI) — National Counterintelligence & Security Center (Office of the Director of National Intelligence): a collection of Research Security reference documents compiled by the National Science Foundation’s (NSF) Office of the Chief of Research Security Strategy and Policy (OCRSSP) regarding best practices in research security for the academic community.
- National Aeronautics and Space Administration (NASA) — Proposers Guide: Section 2.16 (Current and Pending Support) contains specific guidance regarding disclosure of current and pending support with China.
- National Institutes of Health (NIH) — Foreign Interference (NIH Central Resource for Grants and Funding Information): Includes an overview of NIH's principles, case studies, explanations about U.S. government concerns regarding foreign influence, requirements for disclosure of Other Support, Foreign Components, and Conflicts of Interest.
- National Science Foundation (NSF) — Research Security at the National Science Foundation (the NSF Office of the Chief of Research Security Strategy and Policy): Includes a comprehensive overview of Research Security at NSF, including policies, foreign influence and risk mitigation, the benefits of international collaboration, and the Research on Research Security program (RRSP).