“The research security challenges we face are real and serious: some foreign governments, including China’s government, are working hard to illicitly acquire our most advanced technologies. This is unacceptable,” wrote Eric Lander, President Biden’s science advisor and director of the Office of Science and Technology Policy (OSTP). “At the same time, if our policies to address those actions significantly diminish our superpower of attracting global scientific talent—or if they fuel xenophobia against Asian Americans—we will have done more damage to ourselves than any competitor or adversary could. So we need a thoughtful and effective approach.”^[1]

With these words, Lander introduced implementation guidance for National Security Presidential Memorandum-33, which was issued by the Trump administration but has been embraced, on a broad scale, by the current one.

In his Jan. 4 blog post, Lander said he has directed “federal research agencies to work together within the next 120 days to develop model grant application forms and instructions that can be used (and adapted where required) by any federal research funding agency.”

According to Lander, “the goal is for the government to clearly describe what it needs to know and for researchers to be able to report the same information in the same way to the greatest extent possible, regardless of which funding agency they’re applying to.”

The guidance was expected in November, following Lander’s pledge in August that it would be issued within 90 days.^[2] That deadline was missed, but not by much, particularly in comparison to agencies that sometimes take years beyond statutory deadlines to issue guidance or rules.

In some ways the guidance was much as expected, but it also contained some nuances that will require further explanation.