Risk Assessment and Mitigation for Fundamental Research

Beginning in 2024, federal agency sponsors have implemented several requirements with regard to mitigating foreign risk. Dept. of War/Defense, the Public Health Service (NIH), Dept. of Energy and NSF and NASA have issued Risk Matrices. These matrices provide risk factors used to assess fundamental research proposals and mitigations decisions in awarding federal funding. Caltech uses these matrices when developing a Risk Mitigation Plan (RMiP). The Caltech process includes review of a researcher's previous years of publications, patents, collaborators, co-authors, funding and more. A short slide presentation overview can be found here.

Federal funding agencies are employing several strategies to assess fundamental research projects for potential risks to national security and US competitive advantages. These practices are evolving; however, several agencies have published the methodologies and approaches to assessing risk.

Not all agencies look at these indicators, but below are some common factors the sponsoring agency may consider as part of the risk assessment.

• Review of current and pending (other) support pages for current time commitments, available time to carry out the proposed project, and potential overlap between the proposed new project and the individual's current portfolio.
• Participation in Malign Foreign Talent Recruit Programs (prohibited)
• Participation in Foreign Talent Recruitment Programs (not prohibited).
• Funding from organizations in countries of concern, e.g., China, Russia, N. Korea, Iran
• Other relationships with researchers in countries of concern – e.g., formal and information collaboration, joint publications or patents, appointments or positions at institutions
• The risk level of the work, especially research in emerging technology areas
• Indications of incomplete or non-disclosure by the researcher of past relationships.

Some federal sponsors have used some or all the following mitigation strategies over the last year as part of the risk management plan for a specific project.

• Reporting to the program officer of all international travel undertaken by senior/key personnel
• Additional reporting of how research results are shared, particularly with individuals from countries of concern, or the prohibition on sharing pre-publication results of the research
• Termination or agreement not to renew sponsored funding or outside activities with organizations from countries of concern
• No awards for the project selected for funding (primarily Army Research Lab).

Below is the NSF Secure Risk Matrix, which provides a structured framework for identifying, assessing, and prioritizing security risks across agency-funded research and infrastructure.

To use it, Select the Funding Agency, Evaluate Risk Factors, Understand the Degree of Risk, Formulate a Risk Mitigation Plan