Other Support and Foreign Influences

Department of Defense (DOD)

Below is a summary of the DOD’s requirements on Current and Pending Support reporting for DoD funded research and research-related educational activities and its related policy on combating undue foreign influence.

The Department of Defense released its policy on Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education on June 29, 2023. Per its policy:

  • Beginning August 9, 2024, the DoD is prohibited from providing funding to or making an award of a fundamental research project proposal in which a covered individual is participating in a malign foreign talent recruitment program or to a proposing institution that does not have a policy addressing malign foreign talent programs pursuant to Section 10632 of the CHIPS and Science Act of 2022.
  • To mitigate research security risk, the DoD now conducts Risk-Based Security Reviews of DoD-funded research and has published the DoD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions (“Decision Matrix”) that provides factors to inform fundamental research assistance mitigation decisions.

DoD’s definition of “Covered Individual”: An individual at an extramural research institution who contributes significantly to the design and/or execution of a fundamental research projects that is, or if selected for award would be, funded, in whole or in part, by the DoD, and who is considered essential to the successful performance of the fundamental research project. Covered individuals include those listed as key personnel in fundamental research project proposals, such as the principal investigator or co-principal investigators. individuals include those listed as key personnel in fundamental research project proposals, such as the principal investigator or co-principal investigators.

Agency Implementations

LATEST: Army Research Lab Broad Agency Announcements (BAAs) require applicants to submit a signed Privacy Act Statement for each and every key person. Other Defense agencies may follow suit or require other information and/or certifications. Proposers should always check specific funding opportunities or BAAs to ensure all required information, format and signatures are included during proposal preparation.

Broad Agency Announcements (BAAs) from Defense agencies such as DARPA are seeking more detailed disclosures on the sources of support for Principal Investigators and other Key Personnel. National Security Impact Statements are now features of these proposals, with particular attention being paid to plans to transfer technology to U.S. industry and disclosures on whether technologies developed under the contract developed under the contract will be transferred to foreign entities. Proposers are also instructed to disclose any prior instances of transfer of technology to foreign entities.

In a March 20, 2019 memo, the Undersecretary of Defense announced new requirements for all new DoD Notices of Funding Opportunities (NFOs) pertaining to new research and research-related educational activities after April 19, 2019.

Per the memo, DOD Notices of Funding Opportunities (NFOs) pertaining to research and research-related educational activities require proposers to submit the following information for all key personnel – not just the PI and Co-PI – in the Senior Key Person Profile whether or not the individuals’ efforts under the project are to be funded by the DOD:

  • A list of all current projects the individual is working on, in addition to any future (pending) support the individual has applied to receive, regardless of the source.
  • Title and objectives of the other research projects.
  • The percentage per year to be devoted to the other projects.
  • The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
  • Name and address of the agencies and/or other parties supporting the other research projects.
  • Period of performance for the other research projects.

DoD indicates that failure to submit this information may cause the proposal to be returned without further review. DoD also reserves the right to request further details from a proposer before making a final determination on funding the effort.

This information will be used to support protection of intellectual property, controlled information, key personnel, and information about critical technologies relevant to national security. Additionally, this information will be used to limit undue influence, including foreign talent programs, by countries that desire to exploit United States’ technology within the DOD research, science and technology, and innovation enterprise.

Note: This requirement applies only to DOD instruments supporting research and research-related educational activities. For all other types of grants, the capture of the above information is optional.

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