On October 13, the U.S. House Select Committee on China released a new report, How to Stop China’s Theft of America's Taxpayer-Funded Research: The Reforms We Need and Rebuttals to Those Who Oppose Them. The 39-page report provides a rebuttal to arguments the Select Committee has encountered related to research security and makes recommendations to strengthen research security. The report suggests that “the purpose of research security safeguards is not to eliminate international collaboration or undermine scientific progress. Rather, the purpose is to ensure that taxpayer-funded research does not directly or indirectly support foreign military advancement, human rights abuses, strategic competitors, or entities acting contrary to U.S. national security interests.” The report goes into particular detail on how co-authorship is indicative of collaboration, the unequal benefits of collaboration with China, prohibition of collaboration with high-risk entities, the inability of academia to self-police research security risks, and the need to protect federal research funding. The Committee makes the case, with examples, that there is a repeated pattern of intentional compliance failures and not simple clerical errors with reporting. The report acknowledges the continued benefit from contributions of Chinese American researchers, while pointing out the Chinese government’s policy of technology and scientific talent acquisition. The four recommendations are: 1) Pass the Securing Innovation and Research from Adversaries (SIRA) Act: This act (H.R. 8901) would prohibit any federally funded research award or any other form of federal financial assistance for use by an individual or entity listed on a U.S. government restricted entity list or an individual associated with such an entity. The restricted entity list in the act closely follows the current DoW prohibited entity lists. Research collaboration is broadly defined to include co-authorship (as noted in the report), data sharing or processing, material transfer, personnel exchanges, visiting scholar appointments, or joint supervision of students or researchers. The report encourages institutions to proactively implement policies “prohibiting federally funded research collaborations with entities that pose identified national security risks.” 2) Standardized Author Contribution Disclosure Requirements for (at a minimum) Federally Funded Research: Require standardized author contribution statements on publications or other outputs resulting from federally funded research with agencies evaluating enforcement. 3) Create Incentives for Universities That Adopt Strong Research Security Practices: Institutions that exceed minimum research security requirements and “demonstrate a sustained commitment to federal funded research” could be designated as “trusted universities,” which could include incentives such as priority for certain funding opportunities. 4) Government-Wide Adoption of Fact-Based Suspension and Debarment Authorities Beyond Conviction-Based Suspension and Debarments: Agencies should standardize suspension and debarment authorities for research security violations, more aggressively use available administrative false claims authorities, and not treat criminal convictions, civil judgements, or prosecution as prerequisites for administrative accountability. To support the report, the Select Committee released over 700 pages of records (one case was over 200 pages) covering 20 research security cases at U.S. institutions investigated by the National Science Foundation (NSF) Office of Inspector General (OIG), including OIG reports from 2018-2025. The records identify efforts by China to recruit researchers at U.S. institutions in key technology areas. The cases involved undisclosed foreign appointments, participation in talent programs, conflicts of commitment, failure to disclose foreign funding and compensation, and research misconduct. Cases resulted in suspension or termination of awards, debarment of researchers from receiving federal funding or serving as NSF reviewers, and criminal indictments (e.g., wire fraud). Several of the researchers resigned from their positions and left the U.S. for China. The Committee’s reported aim with the release of previously non-public records is to provide greater transparency on the evidence underlying research security investigations and the findings informing the Committee’s recommendations.
Reference Library
Browse and search all federal research security policies, guidance, and compliance requirements.
The National Institutes of Health (NIH) has updated its Current and Pending (Other) Support (CPOS) Common Form page to include Example Scenarios of Monetary Donations Requiring Disclosure. In the document, NIH notes that "Monetary donations given to an institution for use by named senior/key personnel that support their research activities, with an expectation from the donor that the funds be used in a specific way (e.g., pediatric cancer research), and where the donor requests periodic scientific or financial updates, must be disclosed to NIH" via the Current and Pending (Other) Support Form. NIH also notes that: applicants and recipients must disclose donations received within the past year where the activities supported by the donation are ongoing and reporting on activities that have ended is not required. The document includes both scenarios when monetary donations must be disclosed as well as situations when donations are considered unrestricted gifts that do not need to be included in Current and Pending (Other) Support. NIH has also updated its frequently asked questions (FAQ) page to provide specific information on how monetary donations should be disclosed in the Common Form for Current and Pending (Other) Support. Notably, NIH specifies that monetary donations "must be disclosed in the ‘Proposals and Active Projects’ section of CPOS as ‘Current’ support," as "monetary donations are not considered in-kind contributions, nor should they be reported as such."
In collaboration with the Federal Demonstration Partnership (FDP) Research Security Subcommittee, NIH has released a FAQ document on Co-authorship and Foreign Components. The FAQs are based on questions and answers provided during the session "Co-authorship and Foreign Components: A Discussion with NIH Extramural Leadership" held on September 15, 2026, as part of FDP's virtual meeting. The FAQs use a variety of scenarios to clarify when foreign co-authorship or collaboration would likely be considered a "foreign component," requiring NIH prior approval. NIH notes that most foreign co-authorship represents a foreign component, and that if a foreign engagement is expected to result in co-authorship, the institution should seek prior approval. The FAQs list exceptions that are not foreign components or collaborations, including informal scientific conversations, one-way transfers of data or materials, peer review, conference participation, and editing conducted by a former U.S. postdoc who has moved abroad.
On August 27, 2026, the National Institutes of Health (NIH) published guidance to help small businesses navigate foreign risk requirements when applying for SBIR/STTR funding under the Small Business Innovation and Economic Security Act. The guidance, in conjunction with NIH's SBIR/STTR Foreign Disclosure and Risk Management page, directs applicants to evaluate not only their own company, owners, and key personnel but also any consultants, contractors, service companies, and partners who contribute substantively to a project's scientific development or execution. Applicants are advised to assess these individuals and entities, with particular scrutiny for foreign countries of concern, against criteria including: ownership and investment structure; professional and institutional affiliations; active business relationships; recent patent filings; participation in malign foreign talent recruitment programs; and cybersecurity practices. Since foreign risk assessment began in 2023, more than half of the Department of Health and Human Services' (HHS) denials have stemmed from foreign risks tied to consultants or contractors, underscoring the importance of vetting external collaborators before submission. Applicants who clear peer review must later submit a single Foreign Disclosure Form during the Just-in-Time process, after which NIH conducts due diligence and, if a risk is identified, requires applicants to remove it and reapply for a future receipt date.
On July 28, 2026, the federal government issued a new government-wide policy prohibiting federal funding for gain-of-function research deemed to be high-risk and establishing a risk-based oversight framework for other high-risk life sciences work. Issued pursuant to Executive Order 14292, the policy replaces earlier oversight frameworks dating back to 2012 and defines two top-risk categories: dangerous gain-of-function (DGOF) research and international research of concern (IROC). Beyond the funding prohibition, it introduces expanded review, certification, monitoring, reporting, and enforcement obligations for institutions and researchers receiving federal life sciences funding, and it restricts federally supported research conducted in countries deemed to lack adequate biosafety and biosecurity oversight. On the same day, the National Institutes of Health (NIH) issued NOT-OD-26-101, noting that the agency is working to implement the new policy and that research previously paused under related 2025 gain-of-function directives (NOT-OD-25-127 and NOT-OD-25-112) remains suspended pending further guidance.
On July 28, 2026, the federal government issued a new government-wide policy prohibiting federal funding for gain-of-function research deemed to be high-risk and establishing a risk-based oversight framework for other high-risk life sciences work. Issued pursuant to Executive Order 14292, the policy replaces earlier oversight frameworks dating back to 2012 and defines two top-risk categories: dangerous gain-of-function (DGOF) research and international research of concern (IROC). Beyond the funding prohibition, it introduces expanded review, certification, monitoring, reporting, and enforcement obligations for institutions and researchers receiving federal life sciences funding, and it restricts federally supported research conducted in countries deemed to lack adequate biosafety and biosecurity oversight. On the same day, the National Institutes of Health (NIH) issued NOT-OD-26-101, noting that the agency is working to implement the new policy and that research previously paused under related 2025 gain-of-function directives (NOT-OD-25-127 and NOT-OD-25-112) remains suspended pending further guidance.
Per the July 16, 2026, Federal Register, the US Department of Energy (DOE) has finalized regulations establishing permanent conflict of interest (COI), conflict of commitment (COC), and organizational conflict of interest (OCI) requirements for recipients of DOE financial assistance. The rule is effective August 17, 2026. Details on the policy and its impacts will be included in a future Research Security Briefing.
On July 8, 2026, the National Science Foundation (NSF) issued a Dear Colleague Letter (DCL) announcing a forthcoming policy that will bar NSF funds from supporting collaborations with entities on U.S. restricted parties lists. Senior/key personnel will be prohibited from collaborating with restricted entities on NSF-funded projects and will also be prohibited from holding an appointment or position with, or receiving research support from, listed entities for the duration of the NSF award. Per the DCL: "NSF appropriated funds shall not be used for grants, contracts, other transactions or other assistance to an organization if the purpose is to conduct research in collaboration with restricted entities. This funding prohibition also extends to the employees of such restricted entities." In Appendix A, NSF lists 12 restricted party lists, an increase from the current four lists and in near alignment with the Department of War (DoW). To comply, Authorized Organizational Representatives and senior/key personnel will need to certify to this effect at proposal submission, and organizations will be responsible for ensuring awareness of and compliance with the prohibition. NSF notes that this change aligns with the DoW's approach to restricted-party collaborations, with the aim of safeguarding NSF-funded research while promoting consistency and reducing administrative burden. NSF intends to implement the prohibition in Fiscal Year 2027. Per the DCL, questions can be directed to researchsecurity@nsf.gov.
Grant Information Circular issued by NASA on February 5, 2026 to implement the research security training (RST) and certification requirements mandated by Section 10634 of the CHIPS and Science Act of 2022 for all research grant and cooperative agreement proposals submitted to the agency. Covered individuals (PIs, Co-PIs, and Co-Is proposing 10 percent or more effort) must certify on their Biographical Sketch and Current and Pending (Other) Support forms that they completed RST within the 12 months prior to proposal submission, with applicant entities certifying via NSPIRES. Requirements take effect August 5, 2026, and NASA recognizes the NSF SECURE Center's Consolidated Training Module (CTM) as a compliant option.
An NIH Guide Notice issued February 4, 2026 confirming that NIH will not withdraw initial applications, JITs, RPPRs, or Prior Approvals submitted on or after January 25 that fail to use the Common Forms via SciENcv for Biographical Sketches, Current and Pending (Other) Support, and NIH Biographical Sketch Supplements. Instead, NIH will provide a warning message when the Common Forms are not used, while still encouraging applicants and recipients to begin using the Common Forms as soon as possible.
A directive issued January 8, 2026, by Emil Michael, Under Secretary of Defense for Research and Engineering, to strengthen research security measures for all DoD-funded fundamental research and counter foreign influence, intellectual property theft, and exploitation. Key actions include prohibiting DoD funding to entities linked to Chinese military companies or with histories of IP theft, implementing annual compliance checks, and establishing a centralized Fundamental Research Risk Review Repository by FY 2026, along with automated vetting tools, damage assessments, and a common research grant database.
On December 31, 2025, the USDA released a Secretary's Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs), effective immediately, for all future USDA awards. The new General T&Cs include several research security-related requirements, including institutional certification regarding foreign ownership, control, or influence by a country of concern, institutional malign foreign talent recruitment program certification, institutional research security training certification, and institutional certification of Common Form information.
On December 31, 2025, USDA released a Secretary's Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs), applied effective immediately to all future USDA awards. The new General T&Cs include several research security-related requirements: institutional certification regarding foreign ownership, control, or influence by a country of concern; institutional malign foreign talent recruitment program (MFTRP) certification; institutional research security training certification; and institutional certification of Common Form information.
On December 18, 2025, the U.S. House Committee on Science, Space, and Technology's Subcommittee on Investigations and Oversight held a hearing examining the implementation of research security measures under the CHIPS and Science Act and NSPM-33. Witnesses included officials from NSF, NASA, NIH, and DOE.
An FDP overview of the current status of federal research funding agency implementation of research security requirements for researchers and institutions, in accordance with the conditions of the CHIPS and Science Act of 2022 (CHIPS Act) and National Security Presidential Memorandum-33 (NSPM-33).
On December 5, 2025, NSF notified the research community that it is offering a grace period for enforcement of Important Notice No. 149 for proposals submitted between December 2 and December 31, 2025, to accommodate programs with deadlines near the December 2, 2025 effective date. NSF will continue to accept proposals using the previous Biographical Sketch and Current and Pending (Other) Support forms until December 31, 2025; after that date, all proposals must incorporate the new senior/key personnel certifications (research security training within the past 12 months and not being a party to a malign foreign talent recruitment program) required under Important Notice No. 149.
Financial Assistance Letter FAL 2026-02, issued by the U.S. Department of Energy on December 3, 2025, mandating that any DOE notices of funding opportunities (NOFOs), including those from the National Nuclear Security Administration, issued on or after December 3, 2025, require use of the Common Forms via the SciENcv system for Biographical Sketches and Current and Pending (Other) Support (CPS). DOE's adoption of the Biosketch Common Form replaces its prior use of the Resume form, with program offices retaining latitude to specify certain data requirements (such as digital persistent identifier requirements or additional CPS disclosures) within a given NOFO.
Issued December 2, 2025, NOT-OD-26-018 announces NIH's adoption of the Common Forms for Biographical Sketches and Current and Pending (Other) Support. Use of the Common Forms and the NIH Biosketch Supplement is required for applications with due dates on or after January 25, 2026, and for RPPRs and Just-In-Time responses submitted on or after that date, all completed via SciENcv. By February 6, 2026, failure to use the Common Forms generates a submission-blocking error, and the transition incorporates malign foreign talent recruitment program (MFTRP) certifications from institutions and senior/key personnel.
On December 2, 2025, NIH released NOT-OD-26-017 notifying the extramural community that, effective for applications submitted for due dates on or after May 25, 2026, each individual listed as senior/key personnel must certify they have completed research security training (RST) within 12 months of the date of application submission. The certification is collected via the Biographical Sketch in SciENcv. Applicants may use any RST addressing topics mandated under the CHIPS and Science Act, and NIH recognizes completion of the SECURE Center condensed training module (CTM) as compliant.
On November 25, 2025, the National Science Foundation (NSF) released an update to the agency's Important Notice No. 149. The update states that the requirements originally slated to take effect in October 2025 instead take effect on December 2, 2025 as a result of the recent government shutdown. The impacted requirements include: certifications of research security training for senior/key personnel; institutional certifications regarding contracts or agreements with Confucius Institutes; and recipient institutions providing supporting documentation for senior/key personnel activities reported as current and pending (other) support (e.g., contracts, grants, appointment letters) to NSF, upon request.
A COGR overview (November 20, 2025) of the research security-related regulations and frameworks most salient to Technology Transfer Offices, written to help technology transfer professionals navigate practical considerations arising from federal research security requirements.
A matrix that lists policies and requirements under the headings of: Disclosures, Agency Risk Assessment, FCOI & COC, Training, Certifications, and Research Security Program for each federal agency. Per COGR, this tool is frequently updated to reflect the release of new documentation. Updated September 30, 2025.
A chart that compares federal laws, regulations, and policies in the area of science and security. The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy, (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies. Updated September 30, 2025.
In a September 29, 2025, notice (NOT-OD-25-161), the National Institutes of Health (NIH) rescinded the September 11, 2025, notice (NOT-OD-25-154) Implementation of NIH Research Security Policies. Per the notice, 'NIH continues to work with the National Science Foundation and other Federal research agencies to finalize guidance on each of the required elements outlined in the Office of Science and Technology Policy (OSTP) Guidelines for Research Security Programs at Covered Institutions, and to develop a centralized process for recipients to certify compliance.' The notice indicates that the implementation date for the requirements announced in NOT-OD-25-154 have not been finalized, the notice is therefore rescinded, and that 'NIH will issue updated guidance on Research Security requirements in the coming months.'
On September 24, 2025, and effective immediately, NIH issued NOT-OD-25-159, establishing new security, operational, and transparency standards for controlled-access data repositories (CADRs) that store and manage sensitive human research data.