Pentagon Updates Research Security and Funding Decision Guidance

The Pentagon this week issued an updated "decision matrix" to help Defense Department program managers review fundamental research proposals for signs of possible foreign influence and mitigate those risks. The guidance outlines certain activities "prohibited by law" that would bar researchers from receiving Pentagon funding and "describes conditions under which mitigation is required or suggested prior to receiving" the funding.

"This update reinforces the Department’s commitment to safeguarding research critical to U.S. national security and protecting taxpayers’ investment while supporting the scientific openness essential to innovation and discovery," the Office of the Under Secretary of Defense for Research and Engineering said.

The Pentagon said the update makes several "key changes" to the version published in 2023, including:

• a prohibition on collaborations with institutions on the Section 1286 list, which includes entities in China, Russia and elsewhere that pose technology transfer risks to foreign countries of concern
• the removal of the requirement for institutional policies blocking participation in a "malign foreign talent recruitment program while maintaining a prohibition for individual researcher participation"
• the removal of a distinction between “association” and “affiliation”
• revised "trigger dates for expected or suggested mitigation measures"
• a clarification that "co-authorships with listed entities should not be the sole basis for denial of an award but may result in mitigation measures being requested on a project-byproject basis."