Federal Updates and More at COGR Forum

On January 13, 2026, the Council on Government Relations (COGR) held the virtual forum, COGR Forum VI: Adapting to Change, Policy Shifts & Research Impact, that included updates from federal agency staff as well as briefings from COGR staff and committee leaders.  While the presenters spoke to a number of sponsored research areas, the following is a summary of the research security-related topics discussed.
 

National Institutes of Health (NIH)

Michelle Bulls, Director of the NIH Office of Policy and Extramural Research Administration
 

Research Security Training

NIH reminded the community that NIH’s research security training requirement, to comply with the CHIPS and Science Act, goes into effect for applications submitted on or after May 25, 2026.  Covered individuals (for NIH, this is defined as senior/key personnel) will complete this certification on their Biosketch, via SciENcv.  Authorized Organization Representatives (AORs) will complete this certification via their signature on the face page of the application.  (See NIH NOT-OD-26-017 for additional information.)
 

Common Forms Implementation

Use of the Common Forms, via SciENcv, for Biosketches, Current and Pending (Other) Support, and NIH Biosketch Supplements will be required for all NIH applications due on or after January 25, 2026, as well as any Just in Time (JIT), Research Performance Progress Report (RPPR) and Prior Approval submissions on or after that date.  When completing their NIH Common Forms, covered individuals will also certify that they are not a party to a malign foreign talent recruitment program.  (See NIH NOT-OD-26-018 for additional information.)
 

Beginning in February, current SciENcv validation warnings will become errors instead.  There is currently a backlog of helpdesk tickets regarding documents generated from SciENcv that should pass system validation checks but are not.  NIH will not be delaying the transition of warning messages to errors but will handle delayed submissions on a case-by-case basis.  Institutions that encounter errors that delay their ability to submit should log a helpdesk ticket for the issue and include the ticket number when corresponding with NIH.  NIH is aware of the current system issue that prevents covered individuals from entering “0.0” calendar months of effort where appropriate (e.g., for outside consulting engagements) and anticipates that this issue will be resolved soon.
 

With regard to the new category “Monetary Donations” included in NIH’s Disclosure Table with associated examples, the agency will be developing examples of how monetary donations that are not “true gifts” should be reported as part of Current and Pending (Other) Support.
 

NIH intends to post a number of FAQs within the next few weeks to address repeated questions or concerns on both the Common Forms and research security training topics.
 

NIH is also continuing to work with other agencies to develop a central approach to the implementation of research security program requirements.
 

Department of Energy (DOE)

Jeannette Singsen, Senior Advisor, Office of Research, Technology, and Economic Security (RTES)
 

Use of Common Forms

DOE reminded the community that DOE requires the use of the Common Forms for Biosketches and Current and Pending (Other) Support via SciENcv for all notices of funding opportunities (NOFOs) published on January 1, 2026, or later.  For existing awards, the previous format for these documents is still acceptable (provided the terms and conditions of the award are not updated indicating otherwise), though the Common Forms are DOE’s preferred format. DOE’s Common Form for Current and Pending (Other) Support includes covered individuals’ certification that they are not a party to a malign foreign talent recruitment program.  It also includes an Addendum section with additional questions regarding the covered individual’s foreign activities.  DOE is taking a risk-based approach to its use of the Addendum section, and it is only required in a subset of NOFOs.
 

Research Security Training

DOE’s Common Form for Current and Pending (Other) Support also includes certification from the covered individual that they have completed research security training within the past 12 months.  DOE recognizes the SECURE Center Consolidated Training Module as meeting this requirement, though other forms of training are acceptable provided they meet the requirements under 42 USC 19234(c).  As RTES receives questions regarding the research security training requirement, answers are posted to the office’s FAQ page.
 

Transparency of Foreign Connections

Certain DOE NOFOs and awards also require applicants, recipients, and subrecipients to submit Transparency of Foreign Connections disclosures.  DOE has provided a suggested template to meet this requirement.
 

Entity of Concern Prohibition

DOE NOFOs and awards continue to require confirmation that no proposal/award participants, including subrecipients, appear on the 1260H or BIS Entity List, and immediate notification of DOE if an existing participant is found to be on either list.
 

Department of War (DoW)

Jason Day, Research Policy Director
 

DoW has not yet finalized their research security training requirement, but the Department’s goal is to implement the requirement by the beginning of June, to correspond roughly with NIH’s May 25th implementation date.  When DoW does implement this requirement, it plans to accept completion of the SECURE Center Condensed Training Module as fulfilling it.  Concurrent with the research security training requirement, the Department also anticipates issuing new guidance on disclosure of DoW funding (i.e., inclusion of grant numbers) in publications.
 

In response to the January 8 Fundamental Research Security Initiatives and Implementation memorandum (see above), DoW expects there will be few direct impacts on recipient institutions.  While the Department has previously used the 1260H list in its risk mitigation reviews, the January 8 memo fully prohibits them, and DoW’s risk matrix will be updated to reflect this.  The memo also requires DoW Components to complete annual spot-checks on all awards that have research security risk mitigation measures in place and at least 25% of their other fundamental research awards.  The Department may reach out to recipient institutions if questions arise as a result of these reviews.  Forum participants requested that these questions be communicated through AORs and not solely principal investigators.
 

While they are not using the SciENcv platform, DoW is implementing the Common Form formats through the SF424 versions hosted by NSF.  DoW has looked at implementing SciENcv and that remains a long-term goal.  The Department is also looking at consolidating IT systems, with respect to grants and cooperative agreements, across its various research Components.
 

DoW also continues to work with other agencies on harmonized research security program requirements and expects to sign on to them once finalized.
 

National Science Foundation (NSF)

Jason Bossie, Office of Budget, Finance, and Award Management
 

Foreign Financial Disclosure Reporting (FFDR)

NSF noted that the December 8, 2025 Supplement to the Proposal & Award Policies & Procedures Guide (PAPPG) includes the clarification for FFDRs that satellite, branch, or regional campuses that are not direct recipients of NSF funding must report any financial support via the main campus of the recipient institution.
 

Per the request of forum participants, NSF will provide additional messaging to the community when it makes future updates to the FFDR FAQ page.
 

Additional Updates

Kris West, COGR Director for Research, Ethics, and Compliance, noted that COGR is aware of the recent release of USDA’s Standardized Terms and Conditions (see above) and will be following up with the community as they learn more.

Higher Ed Associations Respond to OSTP Request for Information

Across three major higher-education associations’ responses to the White House Office of Science and Technology Policy’s request for information on “Accelerating the American Scientific Enterprise” initiative, there is strong consensus that federal research security policy must both protect sensitive research and avoid unnecessary burdens on researchers. Each group emphasizes the need for harmonized, risk-based, and clearly communicated federal requirements to ensure institutions can meet national-security objectives without undermining scientific productivity.
 

The Association of American Universities (AAU) recommends continued implementation and greater harmonization of NSPM-33 requirements, arguing that aligned disclosure, cybersecurity, and training expectations would strengthen national safeguards while preventing duplicative, inconsistent processes that slow research progress.
 

The Association of Public and Land-grant Universities (APLU) similarly recommends “rightsized” research security requirements that maintain appropriate protections while eliminating conflicting agency-specific rules that increase administrative workload. It urges full standardization of disclosure forms, consistent use of platforms such as SciENcv and iEdison, and clearer federal guidance so institutions can comply efficiently and uniformly.
 

COGR’s letter emphasizes that effective research security must be risk-proportionate and aligned across agencies, warning that the current state of overlapping and sometimes inconsistent foreign-engagement reviews, reporting obligations, and cybersecurity standards create significant administrative strain. COGR urges reaffirmation of NSDD-189, reduction of duplicative requirements, and practical implementation guidance that preserves openness and international collaboration.