Federal Agency Updates

DoD Research Security Guidelines

DoD implemented new guidelines to evaluate risk and establish risk mitigation measures for fundamental research projects. Under these guidelines:

• Researchers’ eligibility for DoD funding may be impacted or require mitigation if they have certain international collaborators or co-authors.
• Equipment from certain international organizations may be prohibited on DoD project.

What does this mean for DoD researchers?

DoD prohibits:

• Certain collaborations: Collaboration on DoD fundamental research projects with an institution (or their employees) on any Prohibited Entity List. The Prohibited Entity Lists are published and updated by DoD.
  • Contact [email protected] for assistance screening potential collaborations.

• Certain equipment: DoD funding used to conduct fundamental research in collaboration with or using equipment from any entity named on a Prohibited Entity List.
  • A question has been added in RAMP (at both pre-award and award) regarding equipment for DoD projects.
  • If you are planning to purchase or use any supplies or equipment (excluding basic office equipment such as computers, laptops, printers), contact the research security team at [email protected] for assistance.

DoD requires mitigation measures if:

• Within the past five years, a covered individual’s co-authors on publications in science and engineering journals are affiliated with an entity on any Prohibited Entity List at the time of review.
• Within the past five years, a covered individual’s co-authors on publications in science and engineering journals are participating in a malign foreign talent recruitment program as defined by the CHIPS & Science Act.

To assist George Mason’s DoD research community:

• The research security team will proactively review publication histories of George Mason researchers funded by DoD or who apply for funding to assist with identifying restricted co-authors or funding in publications.
  • This will enable researchers to be aware of what DoD is reviewing and will help preemptively address any questions related to proposals that may be raised by DoD.
• The research security team will follow up with individual researchers if they have any questions or need clarification on a collaboration.
• The research security team will work with researchers to draft Mitigation Plans if they are required for a particular DoD project.

The research security office is committed to serving as a collaborative partner to assist researchers in navigating evolving DoD requirements. If you have any questions, please contact the research security office at [email protected].  

What is a Foreign Component

NIH requires approval of any “foreign component” which it defines as:

The performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended. Activities that would meet this definition include, but are not limited to:

• the involvement of human subjects or animals at a foreign site,
• extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or
• any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.

Additional Clarification Regarding Co-Authorship

NIH has increased its oversight of foreign collaborations and has provided additional clarification regarding what is a foreign component:

• Collaborations with investigators at a foreign site anticipated to result in co-authorship;
• Use of facilities or instrumentation at a foreign site; or
• Receipt of financial support or resources from a foreign entity.
• Foreign travel for consultation is not considered a foreign component.

According to its written guidance, NIH considers that most instances of co-authorship represent a foreign component. However, NIH recognizes that certain contributions are so minor that they do not constitute an actual collaboration. For example:

• The provision of a single reagent might not be a collaboration but could result in co-authorship.
• Occasionally co-authorship arises through indirect association, such as when an NIH-funded researcher and a foreign researcher both independently work with the same domestic collaborator but only learn of this fact when a manuscript is prepared describing the work.

In all cases, NIH recipients should report foreign co-authorship to the funding Institute or Center as soon as they are aware of it to determine what steps, if any, need to be taken.

Notice of Funding Opportunity (NOFO)

A Notice of Funding Opportunity (NOFO) will outline whether foreign components are permitted. For awards that are issued from NOFOs that do not allow foreign components, publications and other research projects generally should NOT include foreign co-authors or collaborators. For example, funds from Institutional Development Award (IDeA) program grants may not be used to support organizations outside of IDeA states, including foreign components.

Acknowledging NIH Funding

• NIH recently clarified that ALL NIH recipients must acknowledge Federal funding when issuing statements, press releases, requests for proposals, bid invitations, and other documents describing projects or programs funded in whole or in part with Federal money. Importantly, this requirement applies to all publications describing NIH-funded work.
• Recipients are required to state on any publications or products resulting from the award:
  • (1) the percentage and dollar amounts of the total program or project costs financed with Federal money and
  • (2) for NIH programs requiring cost sharing, the dollar amount of the total costs financed by non-governmental sources (i.e., percentage and dollar amount of support from federal and non-federal sources).

• Attributing publications to grants that did not actually support the described work does not align with NIH policy and could inadvertently result in compliance actions.
• If the NIH grant only supported a specific part of the published work, this should be made clear in the grant citation in the publication and in the Research Performance Progress Report.
• NIH-funded investigators should take care to accurately list their affiliations on publications to reflect where they performed the NIH-funded work rather than using their current address if it is different from the performance site.

For more information, please see:

• NIH NOT-OD-26-084, Definition of Foreign Components
• NIH FAQs on Foreign Components
• COGR Foreign Component Discussion June 2026 COGR Meeting

If you have any questions, please contact [email protected].

The research security office is sharing information on a recent NSF Dear Colleague Letter regarding prohibitions on collaborations with restricted entities. The Dear Colleague Letter details new restrictions that NSF intends to implement on October 1, 2026. These upcoming NSF research security rules may affect your eligibility for NSF funding if you have certain international collaborators, co-authors or foreign appointments.

The new restrictions include:

• NSF funds cannot be used if the purpose is to conduct research in collaboration with entities, or their employees, on various U.S. restricted party lists.
• Senior/key personnel are prohibited from collaborating with a restricted entity, or their employees, on NSF-funded projects.
• Senior/key personnel are prohibited from holding an appointment or position with, or receiving research support from, a restricted entity for the duration of the NSF award.

What does this mean for NSF researchers?

At the time of proposal submission, senior/key personnel will be required to certify that they are complying with this prohibition.

To assist George Mason’s NSF research community, the university’s research security team will begin proactively reviewing publication and affiliation histories of George Mason researchers currently funded by NSF (including those with pending proposals) to assist with identifying restricted collaborations or affiliations. This will enable researchers to be aware of what NSF will be reviewing and will help preemptively address any questions that may be raised by NSF. The research security team will follow up with individual researchers if they have any questions or need clarification on a collaboration or appointment.

The research security office will continue to monitor guidance from NSF and will provide any updates as they are announced. We remain committed to serving as a collaborative partner to assist researchers in navigating evolving NSF requirements. Please contact the research security office at [email protected] with any questions.