Department of Defense (DoD) Research Security Guidance

Overview 

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 research security requirements are implemented through Notices of Funding Opportunity (NOFOs), DoD policies and guidance, component-specific requirements, and award terms and conditions. Investigators should review the requirements applicable to their specific funding opportunity and award.

The Office of Research Security (ORS) assists investigators in identifying and addressing DoD research security considerations before proposal submission and throughout the life of an award, including international collaborations, foreign appointments and affiliations, foreign research support, foreign talent recruitment programs, restricted entities, export controls, and other sponsor-specific requirements.

SCHEDULE A CONSULTATION

CONTACT ORS

DoD Research Security Reviews

DoD conducts risk-based security reviews of fundamental research proposals selected for potential award. These reviews occur after scientific merit review and are intended to identify research security risks associated with covered individuals, foreign relationships, research activities, and participating organizations.

DoD uses the DoD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions to support consistent evaluation of identified risks.

The Decision Matrix identifies circumstances that may require additional review or mitigation and distinguishes those circumstances from international research relationships that do not, by themselves, present a research security concern.

Depending on the circumstances, DoD may determine that:

• No additional action is required.
• Additional information is needed.
• A research security risk can be addressed through mitigation.
• A proposed activity or relationship is prohibited by law or DoD policy.
• An identified risk affects the Department's funding decision.

International collaboration is not inherently prohibited or considered a research security risk. DoD's review focuses on the specific individuals, organizations, relationships, activities, and other factors associated with the proposed research.

Key DoD Research Security Considerations

Foreign Talent Recruitment Programs

DoD evaluates participation in foreign talent recruitment programs.

Participation in a Malign Foreign Talent Recruitment Program (MFTRP) is prohibited for covered individuals participating in federally funded research when applicable federal requirements apply and may affect eligibility to participate in a DoD-funded project.

Investigators must ensure that required MFTRP certifications are complete and accurate and should contact ORS before accepting or participating in a foreign talent recruitment program.

Foreign Funding & Research Support

DoD may evaluate foreign research funding, in-kind support, appointments, affiliations, and other relationships disclosed by Senior/Key Personnel.

Particular scrutiny may apply to relationships involving Foreign Countries of Concern, foreign government organizations, foreign institutions, or other entities identified under applicable DoD research security policies.

Investigators should ensure that foreign research support and other required relationships are accurately disclosed in applicable sponsor disclosure documents.

Restricted Entities & Affiliations

DoD evaluates certain appointments, affiliations, collaborations, funding relationships, and other associations involving organizations identified on applicable U.S. Government restricted entity lists.

Some relationships may require additional review or mitigation, while others may be prohibited under federal law or DoD policy.

ORS conducts Restricted Entity Screening and assists investigators in determining whether proposed collaborators, organizations, or other research relationships require additional review.

Patent & Intellectual Property Activities

DoD may consider certain foreign patent and intellectual property activities when evaluating research security risk.

Foreign patent activity does not, by itself, necessarily preclude funding. However, patent filings or intellectual property relationships involving Foreign Countries of Concern or certain foreign-connected organizations may be considered as part of DoD's overall assessment of a proposed project.

Before Proposal Submission

Investigators preparing a DoD proposal should ensure that required research security information and sponsor disclosures are complete, accurate, and current.

Before submitting a proposal:

• Review the funding opportunity for DoD or component-specific research security requirements.
• Complete required Biographical Sketch and Current and Pending (Other) Support documents.
• Disclose foreign appointments, affiliations, research support, and in-kind resources when required.
• Accurately describe international collaborations and participating organizations.
• Complete required research security training.
• Complete required certifications concerning Malign Foreign Talent Recruitment Programs.
• Identify foreign talent recruitment program participation or offers of participation.
• Identify foreign research funding or other relationships requiring disclosure.
• Identify proposed collaborators or organizations that may require Restricted Entity Screening.
• Review applicable sponsor requirements concerning patents, intellectual property, publication, participation, or access.

Contact ORS Before Proposal Submission

Contact ORS if a proposed DoD project involves:

• Foreign appointments or affiliations.
• Foreign research support or in-kind resources.
• Foreign government-sponsored talent recruitment programs.
• International collaborators or foreign participating organizations presenting research security concerns.
• Organizations that may appear on U.S. Government restricted entity lists.
• Relationships involving Foreign Countries of Concern.
• Export-controlled equipment, software, technology, or technical information.
• Restrictions on publication, access, dissemination, or research participation.
• Questions concerning DoD research security disclosures, certifications, or other sponsor requirements.

Early consultation allows ORS to identify potential requirements before proposal submission and coordinate additional institutional review when necessary.

During a DoD Award

Research security responsibilities continue throughout the life of a DoD award.

Investigators should contact ORS when circumstances change in ways that may affect sponsor disclosures or research security requirements, including:

• Accepting a new foreign appointment or affiliation.
• Receiving new foreign research support or in-kind resources.
• Establishing a new international collaboration.
• Adding a new foreign participating organization or collaborator when research security review may be required.
• Participating in, or receiving an offer to participate in, a foreign talent recruitment program.
• Establishing a new relationship involving an organization appearing on an applicable restricted entity list.
• Making changes involving Foreign Countries of Concern that may affect the project.
• Entering into new research-related consulting or other professional arrangements that require disclosure.
• Making material changes to information previously provided in sponsor disclosures.
• Receiving a request from DoD for additional research security information, documentation, or mitigation.

Depending on the circumstances, updated disclosures, sponsor notification, additional institutional review, or research security mitigation may be required.

ORS can assist investigators in determining the appropriate next steps.

Fundamental Research & Other DoD Requirements

DoD's Academic Research Security framework addresses fundamental research and the research security risks associated with that research.

Fundamental research is generally intended to remain open and publishable. DoD guidance emphasizes the importance of maintaining the open research environment and avoiding unnecessary restrictions on fundamental research.

Research that involves additional restrictions or protected information may be subject to separate DoD and institutional requirements.

Examples include research involving:

• Controlled Unclassified Information (CUI).
• Classified information.
• Export-controlled technical information or technology.
• Restrictions on publication or dissemination.
• Restrictions on participation or access.
• Sponsor-required information protection or cybersecurity safeguards.

These requirements are distinct from DoD's risk-based security review of fundamental research and may require additional institutional review.

Investigators should contact ORS whenever a DoD funding opportunity, agreement, or award contains research security, export control, CUI, publication, participation, access, or information protection requirements.

How ORS Can Help

ORS assists investigators throughout the DoD proposal and award lifecycle.

ORS can provide assistance with:

• DoD research security requirements.
• Sponsor disclosure requirements.
• Foreign appointments and affiliations.
• Foreign research support and in-kind resources.
• International collaboration reviews.
• Foreign talent recruitment program reviews.
• Malign Foreign Talent Recruitment Program requirements.
• Restricted Entity Screening.
• Foreign Country of Concern considerations.
• Export control determinations.
• Fundamental research considerations.
• Sponsor-requested research security mitigation.
• Coordination with other University offices when additional institutional requirements apply.

ORS works with investigators, Sponsored Programs, and other University offices, as appropriate, to identify research security requirements early and support compliant management of DoD-funded research throughout the award lifecycle.

Related ORS Resources

Federal Resources

For current DoD research security policies, guidance, risk review tools, and related resources, visit the DoD Academic Research Security website

Need Assistance?

Questions regarding DoD research security requirements should be discussed with ORS as early as possible during proposal development, before initiating new international research activities, or whenever relevant circumstances change during an active award.

Early consultation helps identify applicable sponsor and institutional requirements, address potential research security concerns, and support timely proposal development and award management.

SCHEDULE A CONSULTATION

CONTACT ORS