California State University San Bernardino Department of Defense (DoD) Guidance
California State University, San Bernardino (CSUSB) research community guidance document to ensure compliance with Department of Defense (DoD) regulations for sponsored projects.
I. Guidance Security Statement: DoD Funding Receipt
CSUSB is committed to safeguarding the integrity and security of research funded by the Department of Defense. All DoD-funded projects must adhere to rigorous security standards to protect against the misappropriation of research and unauthorized foreign interference. The university requires a layered security approach that integrates physical, digital, and administrative controls.
II. DoD Research Categories (6.1 – 6.8)
The DoD classifies Research, Development, Test, and Evaluation (RDT&E) into specific budget activity codes. Understanding your project’s category is critical for determining the level of security and export control oversight required.
| Category | Title | Description |
|---|---|---|
| 6.1 | Basic Research | Systematic study directed toward greater knowledge of the fundamental aspects of phenomena. Usually "Fundamental Research" and exempt from many export controls. By DoD policy, 6.1 research is almost always categorized as Fundamental Research. The clause is standard here, allowing for open publication and the involvement of international students without export licenses. |
| 6.2 | Applied Research | Translates promising basic research into solutions for broadly defined military needs. Conditional Application 6.2 research occupies a "gray area." It can be classified as Fundamental Research if the effort is focused on the initial expansion of knowledge. However, if the work has a specific, restricted military application or involves Controlled Unclassified Information (CUI), the clause may be withheld. |
| 6.3 | Advanced Technology Development | Demonstrates the general military utility or cost reduction potential of technology in military equipment. |
| 6.4 | Advanced Component Development | Evaluation of integrated technologies, components, or complete prototypes in a high-fidelity and realistic operating environment. |
| 6.5 | System Development & Demonstration | Development of hardware for Service use before it is approved for production |
| 6.6 | RDT&E Management Support | Support for installations and operations required for general R&D use (e.g., test ranges). |
| 6.7 | Operational System Development | Development, engineering, and manufacturing of systems that have already been fielded. |
| 6.8 | Software & Digital Technology Pilot | Focused on modernizing software and digital technology through agile development and pilot programs |
III. The Fundamental Research Clause
- In the context of Department of Defense (DoD) grants, the Fundamental Research Clause (typically referenced via DFARS 252.204-7000) establishes that the research is excluded from most export control restrictions (such as ITAR or EAR).
- Definition
- Fundamental Research is defined as basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community. It is distinguished from proprietary research and from industrial development, design, production, and product utilization, the results of which ordinarily are restricted for proprietary or national security reasons.
- Key Requirement: For research to maintain this status, the university must ensure there are “no other agreements" or clauses in the grant that allow the DoD to review or approve the results before publication.
IV. Facility & Data Security Requirements
For research categorized beyond 6.1 (and some sensitive 6.1 projects), CSUSB must utilize Designated Research Facilities with the following security specifications:
1. Data Security & Computing
- Encrypted Servers: All project data must be stored on university-managed, encrypted servers using FIPS 140-2 validated modules.
- NIST SP 800-171 Compliance: Facilities must meet the "Protecting Controlled Unclassified Information (CUI)" standards.
- Network Isolation: Highly sensitive projects may require a "Gap-Air" environment or a dedicated subnet isolated from the general campus Wi-Fi.
2. Physical Security
- Access Control: Designated labs must have biometric or keyed-electronic access with real-time logging of all entries and exits.
- Door Security: Doors must be self-closing and self-locking. External windows in these facilities must be reinforced or obscured if sensitive hardware is visible.
- Visitor Logs: All non-project personnel (including janitorial or IT staff) must be escorted and logged.
V. Grant Management Guidelines
To maintain eligibility for DoD funding, CSUSB Principal Investigators (PIs) and administrators must follow these guidelines:
- Financial Transparency: Adhere to the Uniform Guidance (2 CFR 200) for cost principles and audit requirements.
- Disclosure of Support: PIs must disclose all "Current and Pending Support," including foreign talent programs or international collaborations, as required by NSPM-33.
- Timely Reporting: Scientific progress reports (RPPRs) and financial reports must be submitted via the specific DoD portal (e.g., eBRAP or PIEE) according to the award's terms and conditions.
VI. Required Training for DoD Funding
All "Covered Individuals" (Senior/Key Personnel) must complete the following prior to the commencement of work:
1. Research Security Training (NSPM-33)
In accordance with the CHIPS and Science Act of 2022, researchers must complete research security training which covers:
- Cybersecurity and data protection.
- Foreign interference and transparency in disclosures.
- Conflict of interest and conflict of commitment.
2. Human Subjects Research (HSR) Training
If the project involves human participants, the DoD requires more than the standard university training:
- CITI Program: Researchers must complete the Social-Behavioral-Educational or Biomedical HSR modules.
- DoD-Specific Modules: Many DoD components (e.g., Army, Navy, Air Force) require the "DoD-specific" CITI module or an annual refresh rather than the standard three-year cycle.
- HRPO Review: Note that all HSR projects must receive DoD Human Research Protection Office (HRPO) approval after CSUSB IRB approval but before the study begins.