Department of Defense (DoD) Research Security Guidance
The U.S. Department of Defense (DoD) supports fundamental research while protecting national security and maintaining the open exchange of scientific knowledge. Through its Academic Research Security program, DoD conducts risk-based security reviews of certain fundamental research proposals to identify research security concerns and determine whether identified risks can be accepted, mitigated, or, when necessary, preclude funding.
DoD proposal and award requirements are implemented through Notices of Funding Opportunity (NOFOs), DoD policy memoranda, component-specific guidance, and award terms and conditions. Investigators should ensure they understand the research security requirements applicable to their funding opportunity.
The Office of Research Security (ORS) assists investigators throughout the DoD award lifecycle by providing guidance on disclosure requirements, international collaborations, foreign appointments and affiliations, research security training, foreign talent recruitment programs, export controls, and other DoD research security requirements.
How DoD Evaluates Research Security
DoD conducts risk-based security reviews of selected fundamental research proposals using the DoD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions. These reviews are performed after scientific merit review and are intended to identify research security concerns that may require mitigation.
DoD evaluates four primary research security factors involving Principal Investigators and other Senior/Key Personnel.
Foreign Talent Recruitment Programs
DoD evaluates participation in foreign talent recruitment programs. Participation in a Malign Foreign Talent Recruitment Program (MFTRP) is prohibited and may prevent an individual from participating in a DoD-funded project. Other foreign talent recruitment activities may require additional review or mitigation.
Foreign Funding
DoD evaluates current and prior research funding from Foreign Countries of Concern (FCOCs) or entities connected to those countries.
Foreign Countries of Concern currently include:
- People's Republic of China
- Russian Federation
- Democratic People's Republic of Korea
- Islamic Republic of Iran
Patent Activities
DoD may evaluate certain foreign patent activities, including patent filings involving Foreign Countries of Concern or foreign-connected entities, when relevant to the proposed research.
Restricted Entity Affiliations and Collaborations
DoD evaluates appointments, affiliations, collaborations, funding relationships, and other associations involving organizations appearing on applicable U.S. Government restricted-party lists.
Depending on the circumstances, identified concerns may require no action, mitigation, or may affect funding eligibility.
Proposal Development
Before submitting a DoD proposal, investigators should ensure:
- Biographical Sketches and Current and Pending (Other) Support are complete and accurate.
- Foreign appointments, affiliations, and research support are fully disclosed.
- International collaborations are appropriately described.
- Research-related consulting and in-kind research resources are disclosed when required.
- Required research security training has been completed.
- Required certifications, including those related to Malign Foreign Talent Recruitment Programs (MFTRPs), are complete and accurate.
- Proposed collaborators and participating organizations have been reviewed for potential restricted-party concerns.
- Patent activities and intellectual property relationships requiring disclosure have been identified.
Contact ORS Before Proposal Submission If Your Project Involves
- Foreign collaborators or organizations.
- Foreign appointments, affiliations, or research support.
- Foreign government-sponsored talent recruitment programs.
- Collaborators associated with restricted entities.
- Research involving critical or emerging technologies.
- Export-controlled technology, software, equipment, or technical information.
- Publication, access, or participation restrictions.
- Questions regarding DoD disclosure or certification requirements.
Army Research Risk Assessment Program (ARRP)
Certain Army grants and cooperative agreements require review under the Army Research Risk Assessment Program (ARRP). When applicable, the solicitation will identify this requirement, and all identified Senior/Key Personnel may be evaluated as part of the Army's research security review.
Award Management
During an active DoD award, investigators should consult ORS before:
- Establishing a new international collaboration.
- Accepting a new foreign appointment or affiliation.
- Receiving new foreign research support or in-kind resources.
- Entering into a new research-related consulting arrangement.
- Adding new foreign collaborators or participating organizations.
- Filing foreign patent applications related to federally supported research.
- Providing foreign collaborators access to research data, software, equipment, or other research assets.
- Making significant changes affecting project personnel, disclosures, or scope of work.
Depending on the activity, DoD may require updated disclosures, sponsor notification, or implementation of appropriate mitigation measures.
Post-Award Responsibilities
Research security responsibilities continue throughout the life of a DoD award.
Investigators should promptly notify ORS regarding:
- Changes in Current and Pending (Other) Support.
- New foreign appointments or affiliations.
- New foreign research support or in-kind resources.
- New international collaborations.
- Participation in or offers to participate in a foreign talent recruitment program.
- Changes involving restricted entities or Foreign Countries of Concern.
- Material changes affecting sponsor disclosures or award conditions.
- Requests from DoD for additional documentation or clarification.
Early consultation allows the University to determine whether updated disclosures, sponsor notification, or additional institutional review is required.
Activities That May Require Additional Institutional Review
Examples include:
- Foreign appointments or affiliations.
- Foreign research support or in-kind resources.
- Foreign talent recruitment program participation.
- Funding from a Foreign Country of Concern.
- Patent activities involving Foreign Countries of Concern.
- Collaborations or affiliations involving restricted entities.
- Research involving critical or emerging technologies.
- Scientific, budgetary, or commitment overlap.
- Export control, sanctions, Controlled Unclassified Information (CUI), or research cybersecurity requirements.
- Sponsor-requested mitigation measures.
Activities That Are Prohibited or May Affect Funding Eligibility
Examples include:
- Participation in a prohibited Malign Foreign Talent Recruitment Program.
- Certain collaborations with organizations or individuals prohibited under applicable DoD policy.
- Materially incomplete or inaccurate sponsor disclosures.
- Failure to complete required research security training or certifications.
- Failure to disclose required foreign appointments, affiliations, research support, or other reportable activities.
- Failure to implement agreed-upon mitigation measures.
- Failure to comply with applicable DoD award, export control, or cybersecurity requirements.
Fundamental Research and Other DoD Requirements
DoD's Academic Research Security framework primarily applies to fundamental research. Projects involving Controlled Unclassified Information (CUI), classified information, export-controlled technical information, publication or participation restrictions, or applicable cybersecurity requirements may be subject to additional sponsor and institutional requirements.
Investigators should contact ORS whenever a DoD solicitation or award includes research security, export control, cybersecurity, CUI, publication, or access restrictions.
How ORS Can Help
ORS provides assistance with:
- DoD disclosure requirements
- Current and Pending (Other) Support
- Foreign appointments and affiliations
- International collaboration reviews
- Foreign talent recruitment program reviews
- Restricted-party screening
- Army Research Risk Assessment Program (ARRP) guidance
- Fundamental research determinations
- Export controls
- Research cybersecurity and CUI requirements
- Research security consultations
ORS works closely with investigators, Sponsored Programs, Information Security, and other University offices to identify research security requirements early, develop appropriate mitigation when available, and support successful management of DoD-funded research throughout the award lifecycle.