UC Comment Letters

This comment letter responds to the Office of Science and Technology Policy (OSTP) RFI on the proposed Research Security Program Standard Requirements, published March 7, 2023. UC supports stronger research security standards but said implementation is not feasible without federal funding, clearer scope, and more time, especially for institutions managing broad federally funded research portfolios. UC recommends limiting requirements to risk-based federally funded science and engineering R&D, funding compliance costs, extending implementation to at least two years, narrowing travel and training obligations, clarifying cybersecurity expectations, and simplifying export-control and covered-individual definitions.