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NSF SECURE Center
Research Security Briefing

Vol. 2, No. 1
January 9, 2026

The SECURE Center distributes research security briefings and timely alerts via its listserv. The Briefing provides a centralized resource for research security-related information, including new statutory and research funding agency requirements, new or updated federal and community resources, and significant news items and scholarly works. The Center will also assess and provide commentary, interpretation, or implementation considerations on new requirements, notices and resources, working with higher education associations, legal partners, or agencies as needed.

Briefing Contents

Federal Agency News & Updates

USDA Issues Standardized Grant and Cooperative Agreement Terms and Conditions

DoD Issues Fundamental Research Security Initiatives and Implementation Memo

House Subcommittee Hearing on Implementation of Research Security Measures

House Committee Report Claims China Exploits DOE-Funded Research

NIH Posts Scenarios of Monetary Donations as Other Support vs. Gifts

Professional Association Resources & Reports

AAU Response to OSTP Urges Balanced Approach to Research Security and Compliance

FDP Update on Status of Federal Research Security Requirements

AAU: House Passes FY26 NDAA

Research Security News, Reports & Events

IU postdoctoral researcher charged with smuggling E. coli

FDP January 2026 Virtual Meeting Registration Now Open

COGR February 2026 Virtual Membership Meeting Registration Now Open

ASCE 2026 Registration Now Open

RISC Bulletin

NSF SECURE Center Opportunities, Updates & Resources

Updated Version of Consolidated Training Module (CTM) Now Available

New RECR Research Security Training Supplement Available for CHIPS/NSF Requirements

Researchers in Quantum and Computer Science Sought for Input on RS Resources (Rescheduled Dates)

Previous SECURE Research Security Briefings

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Federal Agency News & Updates

USDA Issues Standardized Grant and Cooperative Agreement Terms and Conditions

On December 31, 2025, the U.S. Department of Agriculture (USDA) released a Secretary’s Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs) to be applied, effective immediately, to all future USDA awards. The new General T&Cs include several research security-related requirements, including:

  • Foreign Ownership, Control, or Influence (FOCI) by a Country of Concern (FCOC):  By accepting an award from USDA, the recipient institution is certifying that “they are not currently, and will not in the future, enter into any subawards, contracts, or other agreements, or otherwise provide any form of benefit (material or non-material) through either funded or unfunded work to any foreign person, foreign entity, U.S. citizen, or U.S. entity, that is subject to FOCI by a FCOC or another foreign adversary.”

    Clarification on the details of the scope and parameters of this requirement will be sought as this diverges from broader federal agency practice. Additional information will be included in future Research Security Briefings as it becomes available.
     

  • Institutional MFTRP certification: In addition to covered individuals certifying that they are not participants in a malign foreign talent recruitment program (MFTRP) on Biosketches and Current and Pending (Other) Support via SciENcv, recipient institutions must certify that no individual employed to work on the award is participating in an MFTRP and has not participated in one within the past ten years.

    This appears to diverge from the CHIPS and Science Act requirement (section 10632) that institutions/AORs certify that all individuals identified as senior/key personnel have been made aware of and complied with their responsibility to certify that they are not a party to an MFTRP. In addition, a 10-year lookback is not a requirement under the CHIPS Act or other federal agency implementations under the Act. As the 10-year period predates concerns regarding MFTRPs and the terms definition in the CHIPS Act, institutions do not have such data and would therefore have to collect it on a project-by-project basis based on self-reporting. Further clarification will be sought, as well as confirmation that the certification requirement is only applicable to senior/key personnel, consistent with other federal/agency implementation, and not to all individuals employed to work on the award, as stated.
     

  • Institutional Research Security Training:  Recipient institutions must certify that each individual working on the award, including all personnel on SBIR and STTR projects, has completed research security training “either at the time of application, where applicable, or within the 12-month period immediately preceding the commencement of work on the award” and must also recertify annually. This timing deviates from the CHIPS Act language and current agency requirements (e.g., DOE and NSF) which require the training to be taken within 12 months prior to proposal submission.

    The T&Cs specifically note that the NSF SECURE Center’s condensed training module satisfies this requirement. Clarification will be sought regarding whether this requirement applies to senior/key personnel, consistent with the CHIPS Act and other federal agency requirements, or does in fact refer to “each individual working on the award.”
     

  • Institutional Certification of Common Form Information: By accepting an award from USDA, the recipient institution certifies that the information provided by all individuals working on the award at the time of proposal submission in Biosketches and Current and Pending (Other) Support via SciENcv, including supporting documentation (e.g., copies of foreign appointments, foreign contracts) is current, accurate, and complete. Clarification will be sought to confirm that institutional certification of accuracy and completeness of this information occurs at the time of proposal submission versus the time of award. In addition, confirmation will be sought that the requirement applies to senior/key personnel, consistent with previous federal interpretations and implementations and not “all individuals working on the award.”

DoD Issues Fundamental Research Security Initiatives and Implementation Memo

Emil Michael, Under Secretary of Defense for Research and Engineering at the U.S. Department of Defense (DoD) issued a directive on January 8, 2026, to strengthen research security measures for all DoD-funded fundamental research, aiming to counter foreign influence, intellectual property (IP) theft, and exploitation. Key actions include prohibiting DoD funding to entities linked to Chinese military companies or with histories of IP theft, implementing annual compliance checks, and establishing a centralized Fundamental Research Risk Review Repository by FY 2026. Components must report enforcement activities, nominate high-risk entities, provide annual training for research security personnel, and ensure transparency through grant record management and publication requirements. Additional initiatives include developing automated vetting tools, conducting damage assessments, and creating a common research grant database, with the goal of enhancing accountability and safeguarding U.S. science and technology.

House Subcommittee Hearing on Implementation of Research Security Measures

On Thursday, December 18, 2025, the U.S. House of Representatives Committee on Science, Space, and Technology held a subcommittee hearing, “Research Security: Examining the Implementation of the CHIPS and Science Act and NSPM-33.”  Witnesses at the hearing, held by the Subcommittee on Investigations and Oversight, included:
 

  • Dr. Rebecca Keiser, Acting Chief of Staff, National Science Foundation (NSF)

  • Dr. Daniel Evans, Assistant Deputy Associate Administrator for Research, National Aeronautics and Space Administration (NASA)

  • Dr. Patricia Valdez, Chief Extramural Research Integrity Officer, National Institutes of Health (NIH)

  • Mr. Jay Tilden, Director of Office of Intelligence and Counterintelligence, U.S. Department of Energy (DOE)
     

The hearing examined how federal research agencies are implementing research security requirements amid growing concern that inconsistent guidance, limited resources, and administrative burden are undermining both security and U.S. competitiveness. Members from both parties agreed that research security is a national security imperative, given persistent efforts by foreign adversaries—particularly China—to exploit the openness of the U.S. research enterprise. At the same time, many lawmakers emphasized that excessive bureaucracy, agency and research funding instability, capped indirect costs, and the loss of federal staff risk driving away top talent and weakening the very scientific ecosystem these policies are meant to protect. A central theme was the need for clear, harmonized, and actionable guidance across agencies, so compliance does not depend on which funder or program a researcher engages with.

Agency witnesses described steps taken to strengthen safeguards while trying to preserve openness. NSF highlighted its TRUST framework, prohibition on malign foreign talent recruitment program participation, certifications, training requirements, and the foundation of the SECURE Center and SECURE Analytics. NASA emphasized a shift away from the “honor system” to verified certifications, clarity through standardized disclosures, and agency alignment to minimize administrative burden on scientists. NIH outlined their comprehensive program focused on disclosure, training, use of common forms, and investigative measures. DOE underscored the role of national laboratories, enhanced due diligence and post-award monitoring, and the need for tailored, risk-based mitigation. Across agencies, witnesses acknowledged staffing shortages, uneven institutional capacity—especially for smaller institutions—and the absence of strong interagency coordination, while members repeatedly stressed that Congress must ensure stable funding, harmonization, and oversight to secure U.S. research without sacrificing global collaboration or long-term U.S. leadership.

House Committee Report Claims China Exploits DOE-Funded Research

The U.S. House of Representatives Select Committee on the Chinese Communist Party (CCP) released a report on December 17, 2026, alleging that the U.S. Department of Energy (DOE) has systematically failed to protect DOE-funded research from exploitation by the CCP, particularly by entities tied to China’s defense research and industrial base. Based on a review of publications, grants, and Chinese-language sources, the authors claim that thousands of DOE-funded research papers between 2023 and 2025 involved collaborations with Chinese institutions, with roughly half linked to military- or defense-designated entities. The report states that these collaborations, which span highly sensitive and dual-use fields, such as quantum science, advanced materials, artificial intelligence, semiconductors, nuclear science, and high-performance computing, raise national security, ethical, and reputational concerns.

The authors posit that these risks persist because DOE’s research security framework is fragmented, under-resourced, and slow to adapt, with gaps in vetting, disclosure, post-award monitoring, and interagency coordination. It cites weaknesses such as limited access to grant data, inconsistent risk assessments, inadequate oversight of national laboratories, insufficient scrutiny of foreign affiliations (including China Scholarship Council involvement), and a failure to draw clear boundaries regarding partners implicated in human rights abuses. The report recommends stronger safeguards and legislative action (particularly the SAFE Research Act) to prohibit high-risk collaborations, enhance disclosure requirements, and protect U.S.-funded research.

NIH Posts Scenarios of Monetary Donations as Other Support vs. Gifts

The National Institutes of Health (NIH) Office of Policy for Extramural Research Administration (OPERA) has posted a document providing illustrative scenarios to help investigators and institutions determine when monetary donations must be disclosed as “Other Support” versus when they qualify as unrestricted gifts. The document explains that donations must be reported as Other Support when they are intended to directly support an investigator’s research activities and carry explicit or implicit expectations, such as use for specific projects, placement into an investigator’s research account, or requirements to provide updates to donors.

The scenarios included in the OPERA document correspond with those included in the Office of the Inspector General’s March 2025 review, “Most Institutions That Received NIH Funding Did Not Fully Understand When They Must Report Monetary Donations.”

Professional Association Resources & Reports

AAU Response to OSTP Urges Balanced Approach to Research Security and Compliance

In its December 19, 2025, response to the White House Office of Science and Technology Policy’s request for information on “Accelerating the American Scientific Enterprise” initiative, the Association of American Universities emphasized the importance of:
 

  • Revitalizing and regularly convening the interagency research security working group established by the National Science and Technology Council, to continue the harmonized implementation of National Security Presidential Memorandum 33 across agencies

  • Providing consistent research security policies across all federal agencies

  • Adopting common principles for a risk-based approach that take into consideration, for example, the type of research performed or the location of the research being conducted

  • Avoiding blanket prohibitions and providing targeted protections that go beyond existing controls (e.g., export controls, controlled unclassified information) only when necessary.

FDP Update on Status of Federal Research Security Requirements

The Federal Demonstration Partnership’s Research Security Subcommittee posted an Update on the Status of Federal Research Security Requirements on December 17, 2025. The update provides an overview of the current status of federal research funding agency implementation of research security requirements for researchers and institutions in accordance with the conditions of the CHIPS and Science Act of 2022 (CHIPS Act) and National Security Presidential Memorandum-33 (NSPM-33).


The update includes agency notices, implementation, and resources related to Research Security Training Requirements, Disclosure through Common Form Implementation, Research Security Program Requirements, Foreign Gift and Contract Reporting, and Risk Reviews of Fundamental Research Proposals.

AAU: House Passes FY26 NDAA

On December 12, 2025, the American Association of Universities (AAU) posted a follow-up on the status of the FY26 National Defense Authorization Act (NDAA), that provides a status update on the research security-related provisions that have been included in previous iterations of the bill, which is now pending review by the Senate.  Notably, provisions of concern that AAU and the Association of Public and Land-grant Universities objected to, including the SAFE Research Act), are not included in the final version of the legislation.

Research Security News, Reports & Events

Please note, articles linked below may require a subscription to view.

NSF SECURE Center cannot distribute copies of subscription-based articles.

 IU postdoctoral researcher charged with smuggling E. coli
(Indiana Daily Student, 12/21/2025)

Youhuang Xiang, a J‑1 visa–holding postdoc in Indiana University’s Biology Department, has been federally charged with conspiracy, smuggling, and making false statements after allegedly importing E. coli concealed in a package mislabeled as women’s underwear. Arrested on November 25, 2025, following a Customs and Border Protection inspection in Chicago, Xiang reportedly admitted he knowingly bypassed USDA import-permit requirements and sourced the bacterial strain via his former affiliation with the Chinese Academy of Sciences. The FBI has urged universities to reinforce training and vigilance regarding legal protocols for importing biological materials. (more)

FDP January 2026 Virtual Meeting Registration Now Open

Registration is now open for the Federal Demonstration Partnership (FDP) virtual meeting, January 26-28, 2026.  Information regarding dates and times of research security-related sessions will be included in future SECURE Research Security Briefings as details become available.

COGR February 2026 Virtual Membership Meeting Registration Now Open

Registration is now open for COGR’s virtual membership meeting, taking place February 24-27, 2026.  Information regarding dates and times of research security-related sessions will be included in future SECURE Research Security Briefings as details become available.

ASCE 2026 Registration Now Open

Texas A&M University’s Research and Innovation Security and Competitiveness (RISC) Institute disseminates weekly RISC Media Bulletins, covering topics related to research security, foreign influence, and the intersection of science, technology, and national security.  To join the distribution list for the RISC Bulletin or view previous editions, click here.

Registration is now open for the 2026 Academic Security and Counter Exploitation (ASCE) Program. Next year is the 10th anniversary of the largest research security conference in the world: February 24 - 26, 2026. (more)

RISC Bulletin

NSF SECURE Opportunities, Updates & Resources

Updated Version of Consolidated Training Module (CTM) Now Available

In response to user feedback, the SECURE Center has updated the condensed research security training module to further enhance accessibility. The transcript now includes content that is not narrated in the module. This includes all “knowledge check” on-screen text and text from pop-up windows that contain additional information and links. In addition, links now use content-specific text rather than “click here.” These changes allow users accessing the content through the transcript to have a similar experience as those using the web-based module.  Links to additional materials are now also included in the transcript. The training module and audio files have been updated to reflect the content-specific text. The updated transcript and module files (CTM 1.2) can be found on the training page of the SECURE Center’s website.

New RECR Research Security Training Supplement Available for CHIPS/NSF Requirements

The CHIPS and Science Act of 2022 (Section 10337) directed the National Science Foundation (NSF) to require several additions to Responsible and Ethical Conduct of Research (RECR) training while also expanding the training to faculty and other senior personnel. The additions include “mentor training and mentorship,” already included in some RECR training, and “training to raise awareness of potential research security threats; and Federal export control, disclosure, and reporting requirements.
 

NSF implemented this requirement via Important Notice No. 149.  Originally published on June 30, 2025, with an effective date of October 10, implementation was delayed due to the government shutdown. The new effective date of December 2, 2025, included a grace period for certification through December 31, 2025.  Per the notice, the Authorized Organizational Representative (AOR) is required to certify that the “institution has a plan to provide appropriate training and oversight in the RECR” to personnel supported by NSF to conduct research and that “such training addresses mentor training and mentorship, training to raise awareness of potential research security threats, and Federal export control, disclosure, and reporting requirements.”
 

Training material drawn from the SECURE Center’s condensed training module that meets these requirements has been added to the SECURE Center’s training page. The additional material can be added to institutions’ existing RECR training via their learning management systems or distributed through other channels.

Faculty Researchers at universities, non-profits or other research institutions, who have received federal funding and are working in quantum computing, computer science, and related fields are being invited to volunteer for a short virtual information-gathering session to help shape new tools that support emerging federal research security requirements. The sessions, organized by the NSF-funded SECURE Center, aim to gather researcher perspectives on challenges related to research security and international collaboration required by federal sponsors, with a focus on developing practical, low-burden resources to address these challenges. Participation will directly inform future guidance, training, and tools intended to reduce administrative workload and impediments to international collaborations while safeguarding research. Sessions originally planned for January are now scheduled for:
 

  • Wednesday, February 4, 2026, 12-1:00 pm ET

  • Friday, February 6, 2026, 10-11:00 am ET

  • Wednesday, February 11, 2026, 1-2:00 pm ET

  • Friday, February 20, 2026, 11:00 am-12:00 pm ET

  • Friday, February 20, 2026, 2-3:00 pm ET
     

Faculty researchers are encouraged to share this opportunity with research colleagues who may be interested. Questions or interest to participate should be directed to SECURE Center staff at researchsecurity@nd.edu.

Researchers in Quantum and Computer Science Sought for Input on RS Resources (Rescheduled Dates)

Previous SECURE Research Security Briefings

2026 issues of the Research Security Briefing are available on the SECURE Center website.

A combined, searchable version of all 2025 issues of the Briefing is also available.

Looking to participate in NSF SECURE Center co-creation activities or contribute to weekly briefings?

Contact info@secure-center.org or sign up here.

The information provided by the NSF SECURE Center is intended for general research and educational purposes only. While we strive to ensure the accuracy and reliability of our content, we do not guarantee its completeness, timeliness, or applicability to specific circumstances. Each user is responsible for conducting their own risk assessments and making decisions based on independent judgment.

 

Further, the NSF SECURE Center does not provide professional or legal advice, and users are encouraged to consult qualified professionals before making decisions based on the information found here. The NSF SECURE Center shall not be liable for any damages or costs of any type arising out of or in any way connected with your use of this information. External links are provided for convenience and do not constitute an endorsement of the content or services offered by any third-party resources.

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