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 includes requirements for “foreign travel security.” The requirements also include periodic training for MSU personnel with active federally sponsored research who travel internationally, and reporting obligations for research institutions, with enhanced compliance requirements for travel to the federally designated "Foreign Countries of Concern" (defined as China (including Hong Kong and Macau), Iran, North Korea, Russia, and Venezuela).
- National Security Presidential Memorandum 33 (NSPM-33) and its subsequent implementation guidance documents require MSU to maintain international travel policies for Covered Individuals, defined as MSU employees significantly contributing to federally funded research, including MSU faculty and staff traveling for research, teaching, conference attendance, 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
Given these evolving federal requirements, MSU has implemented a new Research Security Policy “Requirement for Registration of MSU International Travel and Remote Work in MSU’s Global Travel and Remote Work Registry“ effective 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 have been developed to assist MSU Personnel with the registration requirements.
Importantly, the policy also 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 (GTRW) Registry
MSU has launched an updated Global Travel and Remote Work (GTRW) Registry that replaces the legacy Office of Global Health, Safety and Security Global Travel Registry. The new registry connects offices across campus that need to be informed of international travel, will enhance administrative efficiency, and streamline processing of travel requests.
When is Registration Required?
MSU faculty and staff must register their international travel if:
- Traveling internationally for MSU business
- Working remotely outside of Michigan (domestically or internationally) for more than 6 months, or
- Traveler is a Covered Individual (with active federal research funding) traveling internationally for MSU-related Business
When is Registration Not Required?
- MSU students generally do not need to register travel (e.g. study abroad programs) unless the student is named as a Principal Investigator on a federally sponsored research award (e.g. certain federal fellowships designate students as PI’s).
- MSU faculty and staff working remotely in Michigan do not need to register.
- MSU faculty and staff traveling within the U.S. for MSU business do not need to register.
Need Further Assistance?
- For questions related to MSU’s Remote Work Outside of Michigan Policy – contact Human Resources at SolutionsCenter@hr.msu.edu.
- For questions related to MSU business travel and reimbursement – contact Travel at State at concurhelp@msu.edu.
- For questions related to MSU resources for international travel – contact Global Health, Safety, and Security globalsafety@msu.edu.
- For questions related to MSU’s research security requirements – contact the Research Security Program at researchsecurity@msu.edu.
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 from any of my federally sponsored 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.
I have a federal award that is not related to research, do I have to register?
If your federal funding is solely non-research and development related funding (e.g. Upward Bound, Gear Up, etc.) then you may not need to register your international travel, depending on the requirements of your award. However, if you have any federal funding that is research and development related funding, then you must register your international travel if you are a Covered Individual conducting MSU-related Business.