Background
Evolving federal laws and regulations require MSU to maintain records of international travel and remote work as well as enhanced compliance requirements for MSU personnel who travel internationally and also conduct federally sponsored research.
- The CHIPS and Science Act requires MSU to establish a Research Security Program that include requirements for “foreign travel security.” The program must also include periodic training for individuals traveling internationally for research, and reporting obligations for research institutions, with enhanced compliance requirements for travel to the federally designated "Foreign Countries of Concern" (defined as China, Iran, North Korea, and Russia).
- National Security Presidential Memorandum 33 (NSPM-33) and its subsequent implementation guidance documents requires MSU to maintain international travel policies for Covered Individuals, defined as MSU employees significantly contributing to federally funded research, and includes faculty and staff traveling for business, teaching, conference attendance, research purposes, and any offers of sponsored travel that could put a person at risk. NSPM-33 also requires MSU to maintain an organizational record of international travel by Covered Individuals, including disclosure and authorization requirements in advance of international travel, security briefings, periodic training on “foreign travel security,” assistance with electronic device security, and pre-registration requirements.
Research Security Policy for International Travel and Remote Work (Coming Soon)
Given these evolving federal requirements, MSU will soon implement a new Research Security Policy “Requirement for Registration of MSU International Travel and Remote Work in MSU’s Global Travel and Remote Work Registry“ with a proposed effective date of March 1, 2026.
The policy will apply to MSU personnel conducting federally sponsored research who meet the definition of a “Covered Individual” as defined in the policy. The policy also includes a new definition of MSU-related Business travel that will be required to be registered. FAQ’s and other guidance are being developed to assist MSU Personnel with the registration requirements and will be communicated as they are developed.
This policy will reinforce MSU’s current requirement for MSU personnel to register international travel in the Global Travel Registry through the Office of Global Health, Safety, and Security (GHSS). The goal is to strengthen institutional compliance with emerging federal requirements, faculty engagement in external activities, and streamline internal processes.
Importantly, the policy reaffirms MSU’s mission by encouraging faculty to advance education, research, outreach, and economic activities through innovation and external partnerships, while acknowledging that Research Security and related compliance requirements continue to be high priority for federal funding agencies.
Global Travel and Remote Work Outside Michigan Registry (Coming Soon)
To support this policy, MSU will launch a new and improved, updated Global Travel and Remote Work Outside Michigan Registry that updates and replaces the current Office of Global Health, Safety and Security (GHSS) Global Travel Registry. The new Global Travel and Remote Work Outside Michigan Registry will connect units across campus who need to be informed of international travel and is intended to enhance administrative efficiency.
Information Security Practices During Travel
Michigan State University (MSU) personnel travel globally for various purposes, including participation in our highly ranked Study Abroad program, visiting family abroad, and attending conferences. It is crucial to prioritize the security of our devices and the information they contain whenever Spartans are on the move.
Frequently Asked Questions
I’m traveling internationally on vacation and checking my MSU email, does that constitute MSU-related Business?
Typically, no. Accessing, sending, and receiving routine email does not by itself constitute MSU-related Business. However, if you are traveling internationally and will be fulfilling MSU responsibilities, such as teaching, conducting or supporting research, attending or presenting at conferences, delivering lectures, or performing outreach, then this would qualify as MSU-related Business. If you have specific questions, please reach out to MSU’s Research Security Program (researchsecurity@msu.edu) for more information.
I’m a Covered Individual and I’ve been invited to give a lecture at a university overseas. I’m not traveling to present research results from any of my federal grants, do I still need to register?
Likely yes. The new federal requirements are based on your role as a Covered Individual who is conducting MSU-related Business. If the invitation to give a lecture arises because of your role at MSU, and you would not otherwise have been invited or eligible to participate absent your MSU role, affiliation, or appointment, then you are conducting MSU-related Business, regardless of whether you are presenting the results of your federally funded research. However, if the invitation to give a lecture is completely unrelated to your MSU role (such as an invitation to give a lecture or talk in your capacity as your child’s little league coach) then you are not conducting MSU-related Business and do not need to register your travel.
I’m traveling internationally to give a lecture where the trip is paid for entirely by the host institution, do I need to register?
Yes, if you are a Covered Individual conducting MSU-related Business, then you need to register, even travel that is funded entirely by an external organization, host institution, or personal funds. If the invitation to give the lecture arises due to your role at MSU, and you would not otherwise have been invited or eligible to participate absent your MSU role, affiliation, or appointment, then you are conducting MSU-related Business, regardless of who is paying for the travel.
My graduate student is traveling internationally. Do they need to register their travel?
MSU students are typically not Covered Individuals who are required to register their international travel under this Policy. A student is only participating in MSU International Travel and Remote Work when paid in an employment capacity by MSU. Students can be considered MSU employees when listed as a Principal Investigator on a federally sponsored research project (this is typical with some types of fellowships). If you are an MSU student-employee and a Covered Individual, then you would need to register your travel if you are conducting MSU-related Business while traveling internationally. If you have specific questions, please reach out to MSU’s Research Security Program (researchsecurity@msu.edu) for more information.