IARPA is implementing the research security policy of National Security Presidential Memorandum-33 (NSPM-33)[1]. This policy directs federal sponsors of research and development (R&D) to assess whether participants in proposed R&D have potential foreign conflicts of interest or conflicts of commitment that pose risks to the security of the R&D. The goal is to identify any such risks and mitigate these risks where possible prior to being considered for award.
NSPM-33 requires “covered individuals” to submit two types of disclosure forms prior to being considered for award. These forms consist of 1) biographical sketches for key personnel and 2) data on current and pending support. IARPA has elected to adopt the common forms developed by the Office of Science and Technology Policy (OSTP) and currently maintained by the National Science Foundation (NSF) for both the biographical sketch and current and pending support disclosures. In the future, “covered institutions” (further described below) must certify that they have a research security program (RSP) consistent with the guidance published by OSTP[2]. IARPA is partnering with the NSF to certify RSP compliance of covered institutions.
Covered Individuals
IARPA designates “covered individuals” as “key personnel” on an R&D proposal who meet the following criteria:
Covered individuals typically include Program Managers (PM), Principal Investigators (PI), Project Managers (PM), and paid research staff, etc.
Some key elements of the NSF biographical sketch disclosure common form[3] for covered individuals include:
Some key elements of the NSF current and pending support disclosure common form[4] for covered individuals include:
IARPA will use a 3-tiered risk assessment model to evaluate covered individual disclosures for foreign conflicts of interest or conflicts of commitment that may indicate potential undue foreign influence, and other risk factors relating to professional and financial activities.
IARPA requires completed disclosure forms to be submitted with each proposal. When medium risk is identified for a performer being considered for an award, IARPA will work with potential performer prior to award to mitigate the identified risk through a mutually acceptable risk mitigation plan.
If IARPA receives a proposal to a Broad Agency Announcement (BAA), or any other solicitation, without the required disclosures, or the disclosure forms contain inaccurate or incomplete information, IARPA may determine that the proposal is not compliant and reject the submission, eliminating it from further consideration. IARPA also reserves the right to request further clarification or detail from potential performers regarding their disclosures or certifications before making the final determination on risk.
Covered Institutions
OSTP issued additional guidelines[5] in July, 2024 defining “covered institutions” as entities who meet the following criteria:
Many institutions participating in IARPA funded R&D meet these criteria. Please note that all covered institutions must certify that they have 1) a compliant policy regarding foreign talent recruitment programs (FTRP) and malign foreign talent recruitment programs (MFTRP) pursuant to Sections 10631 and 10632 of the CHIPS and Science Act of 2022[6] and that 2) no covered individuals (as designated above) in the proposal are part of such a program. IARPA requires these completed certifications to be submitted with each proposal.
In the future, covered institutions must also certify in writing or electronically that they have a fully-compliant RSP. The RSP must address four separate areas:
While OSTP’s current guidance offers multiple ways for a covered institution to satisfy the RSP requirements, this guidance is still under review by NSF, who has a leadership role in implementing the administration of RSP certification. Please note that IARPA will be adopting NSF’s final guidance for validating RSP certification (see NSF’s website for additional information on the RSP requirements). Since the RSP certification deadline has yet to be finalized, IARPA will accept proposals from covered institutions in the process of implementing RSPs, but which are not yet certified as NSPM-33 compliant.
1 2021, OSTP NSPM-33, Presidential Memorandum on United States Government-Supported Research and Development National Security Policy, National Security & Defense, Issued on: January 14, 2021 [Presidential Memorandum on United States Government-Supported Research and Development National Security Policy – The White House]
2 2022, Guidance for Implementing National Security, Presidential Memorandum 33 (NSPM-33), Report by the Subcommittee on Research Security, Issued January 2022 [010422-NSPM-33-Implementation-Guidance.pdf]
3 NSF Biographical Sketch Common Form [ https://www.nsf.gov/bfa/dias/policy/researchprotection/commonform_biographicalsketch.pdf ]
4 NSF Current and Pending (other) Support Common Form [ https://www.nsf.gov/bfa/dias/policy/researchprotection/commonform_cps.pdf ]
5 OSTP Guidelines for Research Security Program at Covered Institutions, July 9 2024 [OSTP-RSP-Guidelines-Memo.pdf]
6 2022 Chips and Science Act, Subtitle D—Research Security, [H.R.4346 - CHIPS and Science Act]
