Risk Assessments for Research Security in Fundamental Research

Federal funding agencies are employing several strategies to assess fundamental research projects for potential risks to national security and US competitive advantages. These practices are evolving; however, several agencies have published the methodologies and approaches to assessing risk.

Not all agencies look at these indicators, but below are some common factors the sponsoring agency may consider as part of the risk assessment.

• Review of current and pending (other) support pages for current time commitments, available time to carry out the proposed project, and potential overlap between the proposed new project and the individual's current portfolio.
• Participation in Malign Foreign Talent Recruit Programs (prohibited)
• Participation in Foreign Talent Recruitment Programs (not prohibited).
• Funding from organizations in countries of concern, e.g., China, Russia, N. Korea, Iran
• Other relationships with researchers in countries of concern – e.g., formal and information collaboration, joint publications or patents, appointments or positions at institutions
• The risk level of the work, especially research in emerging technology areas
• Indications of incomplete or non-disclosure by the researcher of past relationships.

Some federal sponsors have used some or all the following mitigation strategies over the last year as part of the risk management plan for a specific project.

• Reporting to the program officer of all international travel undertaken by senior/key personnel
• Additional reporting of how research results are shared, particularly with individuals from countries of concern, or the prohibition on sharing pre-publication results of the research
• Termination or agreement not to renew sponsored funding or outside activities with organizations from countries of concern
• No awards for the project selected for funding (primarily Army Research Lab).

• DOE – For the last several years, DOE has required prior approval before some foreign nationals may participate in DOE-funded fundamental research - DOE Order 486.1A. In addition, DOE National Labs are subject to the Science and Technology Risk Matrix (S&T Risk Matrix).
• DOD, including DARPA – Department of Defense Academic Research Security page- https://basicresearch.defense.gov/Programs/Academic-Research-Security/ including the Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education – June 2023
• Army Research Lab (ARL) – more stringent oversight than DOD matrix - Army Futures Command (AFC) Army Research Risk Assessment Protection Program (ARRP)
• NSF – Trusted Research Using Safeguards and Transparency (TRUST) framework will be piloted in the future for quantum physics projects funded by the NSF – June 2024. NSF plans to implement this framework for quantum physics projects reviewed after October 1, 2024.
• NIH – Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel documents and consolidates existing NIH policies and practices – August 2024. In addition, a new OSTP policy for dual-use technology - Policy for Oversight of Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential (May 2024) - is designed to strengthen oversight of life sciences research with biological agents and toxins.