Research Security and the Cost of Compliance

Download COGR's "Research Security and the Cost of Compliance"

View COGR Presentation on "Research Security & the ROI"

"The projected year one, average total cost per institution for compliance with the Disclosure Standards, regardless of institutional size, is significant and concerning. The figure ranges from an average of over $100,000 for smaller institutions to over $400,000 for mid-size and large institutions. Although some of these expenses are one-time costs, a sizeable portion will be annual recurring compliance costs. Overall, the cost impact to research institutions in year one is expected to exceed $50 million. "

COGR Results from COGR’s Phase I Survey on the Costs of Complying with Research Security Disclosure Requirements

Gathered from 26 complete answers examining institutional costs for fiscal year 2022-23 

Over the past four and a half years, universities and their affiliated academic medical centers (AMCs) and research institutions have focused on addressing federal funding agency requirements adopted to address inappropriate foreign influence on research. These requirements include new and clarified provisions calling for researchers to disclose all sources of research support and all types of appointments and affiliations (“Disclosure Requirements”) so that agencies and institutions will have the information they need to identify any areas of commitment, funding, or scientific overlap. These Disclosure Requirements are set forth in the Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33) on National Security Strategy for United States Government Supported Research and Development1 (“Implementation Guidance”) and in agency notices.

COGR conducted Phase I of the survey described in this report to quantify the considerable time and resources (financial and otherwise) that research institutions have invested (or will invest) to achieve compliance with the Disclosure Requirements.

Source: https://www.cogr.edu/june-9-10-2022-cogr-meeting-presentations

Higher Education public webpages on NSPM-33

Cornell University - Research Security

Emory University - NSPM-33 Compliance Plan

Indiana University - National Security Presidential Memorandum 33

University of California, Berkeley - National Security Presidential Memorandum 33

University of Georgia - Research Security

University of Houston - NSPM-33

University of Notre Dame Research

Higher Education Response to NSPM-33

Higher Education Presentations