NSPM-33

NSPM-33 was signed January 14, 2021, in the final week of the first Trump administration, directing the White House Office of Science and Technology Policy (OSTP) to lead a government-wide effort to align research-security policy across federal research-funding agencies. Implementation continued under the following administration: OSTP, through the National Science and Technology Council (NSTC), issued formal NSPM-33 Implementation Guidance in January 2022 — the document agencies actually build their disclosure rules from.

What the Implementation Guidance requires

The guidance sorts affected researchers into two disclosure tiers. Tier I covered individuals — principal investigators, co-PIs, and other senior/key personnel — must disclose all professional positions and appointments (domestic and foreign, paid or unpaid) and all resources supporting their research (financial or in-kind, domestic or foreign), including foreign talent recruitment program participation, regardless of the level of effort or compensation involved. This is implemented through each agency’s Biographical Sketch and Current and Pending Support forms. Tier II covered individuals — peer reviewers and advisory committee or panel members — face a narrower, conflict-of-interest-focused disclosure obligation tied to the specific applications or portfolios they review.

Agencies were also directed to require a standardised research security program at institutions receiving more than $50 million a year in federal research funding, covering cybersecurity, foreign travel security, insider-threat awareness, and export control training; see the four required program elements for the detail. NSF, NIH, DOE, NASA, USDA, and DOD have each rolled the Common Form and training requirements into agency-specific policy on staggered timelines — NSF adopted the SciENcv-based Common Form for proposals due on or after January 30, 2023, while NIH’s equivalent mandate did not take effect until applications with due dates on or after January 25, 2026.

NSPM-33 itself is a presidential policy directive, not a statute, and creates no penalties on its own; its consequences flow through each agency’s grant terms and, for a narrower set of conduct, through the CHIPS and Science Act, which independently codified the malign foreign talent recruitment program certification and training requirements NSPM-33 also calls for. See Research security policy for how institutions build these disclosure obligations into a working compliance program, and Covered Individual under NSPM-33 for exactly who the Tier I/II categories apply to.

Checking this against the current guidance

Which agency’s rollout timeline and Common Form version actually applies to your project depends on which federal agency funds it and, where more than one does, whose disclosure requirement governs. The answer depends on which funding agency’s own rollout timeline you are working to, and the page above states the general rule.

Ask CASRAI: Our PI already filed Current and Pending Support under NSF’s Common Form for an active award — if DOE later becomes a co-funder on the same project, do they require their own separate Tier I disclosure, or does NSF’s already-filed form satisfy DOE too?

It searches CASRAI’s indexed corpus of research-administration guidance and cites the passage behind each claim, so you can open the source and check it rather than take its word — and it says so when the corpus does not cover something instead of guessing. Two questions a day are free while you are signed out, no account and no card. Everything CASRAI publishes stays free to read.

Frequently asked questions

If a project already has NSPM-33 Tier I disclosures filed under one agency’s Common Form, does a second co-funding agency require its own separate disclosure?

NSPM-33’s Implementation Guidance sets the disclosure categories, but each federal agency adopted the Common Form and enforces it on its own timeline and through its own award terms — NSF from proposals due January 30, 2023, NIH not until applications due January 25, 2026. A filing accepted by one agency is not automatically treated as satisfying a second agency’s own requirement; check the specific co-funder’s current policy.

Is a postdoc paid entirely from non-federal funds a Tier I covered individual?

Tier I status turns on the role — PI, co-PI, senior/key personnel — not on the funding source of that person’s salary. A postdoc named as senior/key personnel on a federally funded project can be a covered individual even if paid from a non-federal line, though the specific facts of the appointment are worth confirming against current agency guidance.

Do Tier II peer reviewers have to disclose the same things as Tier I senior personnel?

No. Tier II individuals — peer reviewers, advisory committee or panel members — face a narrower, conflict-of-interest-focused disclosure tied to the specific applications or portfolios under review, not the full appointments-and-resources disclosure Tier I personnel must make.

Does NSPM-33 itself create legal penalties for non-compliance?

No. NSPM-33 is a presidential policy directive, not a statute, and creates no penalties on its own; consequences flow through each agency’s own grant terms and, for a narrower set of conduct, through the CHIPS and Science Act’s own certification and training requirements.