The document summarizes the experiences of U.S. research institutions with the Department of Defense’s (DoD) policy for risk-based security reviews of fundamental research, particularly in response to heightened concerns about foreign influence in academia. Following the June 2023 publication of DoD’s risk assessment policy and decision matrix, the Council on Governmental Relations (COGR) conducted a survey among its member institutions to assess the impact and implementation of these new requirements. The survey, which included 82 institutions, found that about half had received requests for research security risk mitigation plans—predominantly from Army/ARL entities. However, most institutions reported a lack of clear rationale from DoD components for why such plans were necessary, and nearly all had to develop plans from scratch due to the absence of provided templates.
The process of drafting and negotiating these mitigation plans often proved time-consuming, with many institutions citing delays in award processing and inconsistent outcomes. Approximately two-thirds were successful in finalizing plans, but more than one-third experienced rejections from DoD, frequently with no explanation provided. Common mitigation measures included requirements for international travel reporting, threat awareness training, and restrictions on collaborations with entities in countries of concern, as defined by U.S. federal law. The survey concludes that clearer communication from DoD components—such as standardized templates, transparent reasoning for mitigation requirements, and defined expectations—would facilitate greater efficiency and compliance. Institutions are advised to anticipate the need for risk mitigation plans as a condition of DoD funding and to prepare for potential challenges in the negotiation and approval process.
Kristin West
Kristin (Kris) West is the Director of the Research Ethics and Compliance Committee at COGR.
