/Office for Research and Innovation
Research Security

National Science Foundation (NSF) Research Security Guidance

The National Science Foundation (NSF) supports open scientific collaboration while promoting transparency, responsible stewardship of federally funded research, and protection of the U.S. research enterprise. NSF research security requirements are implemented through the Proposal & Award Policies & Procedures Guide (PAPPG), applicable NSF policy notices, and award terms and conditions.

The Office of Research Security (ORS) assists investigators throughout the NSF award lifecycle by providing guidance on disclosure requirements, international collaborations, research security training, foreign talent recruitment programs, and other sponsor-specific research security requirements.

How NSF Evaluates Research Security

The NSF Office of the Chief of Research Security Strategy and Policy (OCRSSP) administers the agency's research security program through the Trusted Research Using Safeguards and Transparency (TRUST) framework. TRUST is intended to promote transparency, support responsible international collaboration, and protect the integrity and security of NSF-funded research.

The TRUST framework evaluates proposals and awards in three complementary areas:

Transparency

NSF evaluates whether required information has been accurately disclosed, including:

  • Professional appointments and positions
  • Current and Pending (Other) Support
  • In-kind research support
  • International collaborations
  • Foreign government-sponsored talent recruitment programs

Compliance

NSF reviews proposals and awards for compliance with disclosure and award requirements, including research security training, annual certifications, and sponsor reporting requirements.

Foreseeable National Security Considerations

Under the TRUST framework, NSF may evaluate whether certain research in critical and emerging technologies presents foreseeable national security considerations requiring additional review or safeguards.

Collaborations with Restricted Entities

NSF has announced a forthcoming research security policy that will prohibit certain collaborations between NSF-funded Senior/Key Personnel and organizations identified on specified U.S. Government restricted-party lists. Investigators considering new international collaborations should consult ORS early in the proposal development process to determine whether the policy may apply.

Once implemented, the policy will prohibit Senior/Key Personnel from:

  • Collaborating on NSF-funded projects with restricted entities or their employees.
  • Holding an appointment or position with a restricted entity during the period of an NSF award.
  • Receiving research support from a restricted entity while serving as Senior/Key Personnel on an NSF award.

Investigators should contact ORS before establishing new international collaborations or accepting appointments or research support from foreign organizations to determine whether additional review is required. Organizations and Senior/Key Personnel will be required to certify compliance with these requirements at proposal submission once the policy becomes effective.

Proposal Development

Before submitting an NSF proposal, investigators should ensure:

  • Biographical Sketches are complete and accurate.
  • Current and Pending (Other) Support is complete.
  • Foreign appointments and positions are disclosed.
  • In-kind resources are appropriately reported.
  • Required research security training has been completed.
  • Required MFTRP certifications are complete and accurate.
  • Outside appointments and research support have been reviewed for consistency with NSF disclosure requirements.
  • Proposed collaborators are not subject to applicable NSF restricted-entity prohibitions.
  • Supporting documentation for appointments, employment, and research support is available if requested by NSF.

Contact ORS if the proposal involves:

  • International collaborators
  • Foreign organizations
  • Foreign appointments
  • Foreign research support or research-related consulting arrangements
  • Critical or emerging technologies
  • Export-controlled research
  • Questions regarding NSF disclosure requirements

Award Management

During an active NSF award, investigators should consult ORS before:

  • Establishing a new international collaboration.
  • Accepting a new foreign appointment or position.
  • Receiving foreign research support or research-related consulting arrangements
  • Adding a new foreign collaborator.
  • Beginning work with a foreign organization.
  • Providing access to research data, technology, software, or other research assets to a foreign collaborator.
  • Accepting a new research-related consulting arrangement.
  • Receiving new in-kind research support or externally provided research resources.
  • Making significant changes affecting disclosures or project scope.

Depending on the activity, additional institutional review, updated disclosures, sponsor notification, or other management measures may be required.

Post-Award Responsibilities

Investigators should notify ORS regarding:

  • Requests from NSF for additional research security documentation or clarification.
  • Changes in Current and Pending (Other) Support.
  • New appointments or affiliations.
  • New foreign research support.
  • Participation in foreign talent recruitment programs.
  • Annual MFTRP certification requirements.
  • Material changes affecting NSF disclosures.

Activities That May Require Additional Institutional Review

Examples include:

  • Research-related consulting arrangements.
  • Undisclosed in-kind research support.
  • New foreign appointments or affiliations.
  • New foreign research support.
  • New international collaborations.
  • Potential scientific, budgetary, or commitment overlap.
  • Export control or sanctions concerns.
  • Research involving critical or emerging technologies.

Activities That Are Prohibited or May Affect Funding Eligibility

Examples include:

  • Participation by Senior/Key Personnel in a prohibited Malign Foreign Talent Recruitment Program.
  • Materially incomplete or inaccurate NSF disclosures.
  • Failure to complete required research security training or certifications.
  • Collaboration on an NSF-funded project with a restricted entity, when prohibited under applicable NSF policy.
  • Holding an appointment or position that is prohibited under applicable NSF research security requirements.
  • Receiving research support from a restricted entity while serving as Senior/Key Personnel on an NSF award.

How ORS Can Help

ORS works closely with investigators, Sponsored Programs, Export Controls, Information Security, and other University offices to address research security questions early, helping investigators maintain compliance while supporting successful international research collaborations.

ORS provides assistance with:

  • NSF disclosure requirements
  • Current and Pending (Other) Support
  • Foreign appointments
  • International collaborations
  • Foreign research support or research-related consulting arrangements
  • Research security training
  • MFTRP questions
  • Export controls
  • Research security consultations