Federal Sponsor Risk Matrices

Overview 

Federal research sponsors have established research security requirements to promote transparency, safeguard federally funded research, protect research integrity, and strengthen the security and resilience of the U.S. research enterprise.

Although many requirements are based on common federal policies and standards, each sponsor implements research security through its own policies, proposal requirements, award terms and conditions, disclosure requirements, certifications, and other agency-specific requirements.

The Office of Research Security (ORS) maintains Federal Sponsor Risk Matrices to help investigators identify research security considerations associated with research funded or proposed for funding by federal agencies.

The matrices provide sponsor-specific guidance regarding activities, relationships, affiliations, and other circumstances that may require disclosure, institutional review, sponsor notification or approval, or additional consideration under the applicable sponsor's research security requirements.

ORS assists investigators in identifying and addressing research security considerations before proposal submission and throughout the life of an award, helping to support compliant, collaborative, and internationally engaged research.


Sponsor-Specific Considerations

Research security requirements vary by federal sponsor. Investigators should review the guidance for the agency funding, or being asked to fund, their research.

Sponsor-specific risk matrices are available for:

National Institutes of Health

National Science Foundation  

Department of Defense

Department of Energy

National Aeronautics and Space Administration

Federal research security requirements and agency guidance may change. Investigators should consult the applicable sponsor-specific matrix and contact ORS when questions arise.


What the Risk Matrices Address

Federal sponsors may evaluate different activities, relationships, and circumstances when assessing research security considerations. Depending on the sponsor and proposed or funded research, the risk matrices may address:

  • International research collaborations and foreign institutional relationships.
  • Foreign appointments, affiliations, and professional activities.
  • Foreign-sponsored research and other sources of research support.
  • Foreign talent recruitment programs.
  • International visitors and research personnel.
  • International travel and research activities conducted outside the United States.
  • Research agreements and other international arrangements.
  • Countries, organizations, or individuals subject to federal restrictions or heightened scrutiny.
  • Export-controlled technology, software, equipment, or technical information.
  • Controlled, restricted, or otherwise protected research information.
  • Sponsor-specific cybersecurity or information protection requirements.
  • Activities requiring institutional review, sponsor notification, prior approval, certification, or other action.

The applicable requirements depend on the sponsor, funding opportunity, award terms and conditions, research activity, participating individuals and organizations, and other project-specific circumstances.


When to Review a Sponsor Risk Matrix

Investigators should review the applicable sponsor-specific risk matrix when:

  • Preparing a proposal for federal funding.
  • Planning a new international collaboration or research activity.
  • Adding a foreign collaborator, institution, subrecipient, consultant, or other research partner.
  • Considering a foreign appointment, affiliation, or other professional relationship.
  • Receiving foreign funding, support, resources, or in-kind contributions related to research.
  • Planning research-related international travel or activities outside the United States.
  • Adding international activities or relationships to an active federally sponsored project.
  • Circumstances change during the life of an award in a way that may affect sponsor research security requirements.
  • They are uncertain whether an activity, relationship, or affiliation requires disclosure, institutional review, sponsor notification, or prior approval.

Investigators are encouraged to consult ORS early when questions arise. Requirements that can be addressed during proposal development are generally easier to manage than issues identified after an activity or commitment has begun.


Sponsor Risk Matrices and Disclosure Requirements

The Federal Sponsor Risk Matrices and Federal Sponsor Disclosure Requirements serve related but different purposes.

Federal Sponsor Risk Matrices help investigators identify research security considerations associated with activities, relationships, affiliations, organizations, countries, and other circumstances that may require additional review or action under a sponsor's requirements.

Federal Sponsor Disclosure Requirements provide guidance regarding sponsor-required disclosure documents and reporting obligations, including Biographical Sketches, Current and Pending (Other) Support, Other Support, Foreign Components, and applicable Common Forms.

An activity or relationship identified through a sponsor risk matrix may also create a disclosure obligation. Investigators should consult both resources when applicable.

VIEW FEDERAL SPONSOR DISCLOSURE REQUIREMENTS


How ORS Supports Investigators

ORS works with investigators before proposal submission and throughout the life of an award to identify and address research security considerations.

Depending on the activity and sponsor requirements, ORS may assist with:

  • Research security consultations.
  • International collaboration reviews.
  • Foreign sponsor reviews.
  • International visitor reviews.
  • International travel consultations.
  • Restricted Entity Screening.
  • Export control determinations.
  • Review of foreign appointments, affiliations, or other international activities.
  • Sponsor-specific research security requirements.
  • Research information protection and cybersecurity coordination.
  • Sponsor disclosure guidance.
  • Coordination with Sponsored Programs and other University offices, as appropriate.

ORS helps investigators identify applicable requirements early, determine what additional review or action may be necessary, and support compliant research throughout the proposal and award lifecycle.


Related Resources

Resource Description
Federal Sponsor Disclosure Requirements Guidance regarding sponsor-specific disclosure documents and reporting requirements, including Biographical Sketches, Current and Pending (Other) Support, Other Support, Foreign Components, and Common Forms.
Research Activities & Guidance Activity-based guidance for international collaborations, foreign-sponsored research, international visitors, travel, agreements, information sharing, and other research activities.
Countries of Concern Information about countries subject to federal research security requirements or heightened institutional review.
Restricted Entity Screening Guidance regarding screening individuals and organizations against U.S. Government restricted party and restricted entity lists.
Export Controls Information about U.S. export control requirements that may apply to federally sponsored research, international collaborations, controlled technology, foreign person access, international transfers, and other research activities.
Research Security Training Information about University and federally required research security training.
Disclosure Requirements Information about institutional and sponsor disclosure requirements related to research activities and outside relationships.

Need Assistance?

Federal sponsor research security requirements vary by agency, funding opportunity, award, and research activity and may change over time.

Investigators should contact ORS during proposal development, before beginning new international research activities, or whenever activities, relationships, affiliations, or other circumstances change during the life of a federally sponsored award.

Early consultation helps identify applicable sponsor requirements, determine whether institutional or sponsor review is required, and support compliant, collaborative, and internationally engaged research.

CONTACT ORS

SCHEDULE A CONSULTATION