In response to NSPM-33 and federal regulations safeguarding the research enterprise, federal research agencies have implemented risk reviews of fundamental research proposals and have published decision matrices, outlining the factors to be considered and the resulting mitigation required. While all agencies now prohibit the funding of a project if a covered individual is actively participating in a Malign Foreign Talent Program, the agencies differ in the consideration of other factors indicating risk. Please see the chart below for an overview of risk factors considered by federal sponsors.
Risk Factor Considerations per Agency
| Agency | Risk Factor 1: Participation in Malign Foreign Talent Recruitment Programs |
Risk Factor 2: Foreign Funding Sources |
Risk Factor 3: Patents |
Risk Factor 4: National Security Implications/Critical and Emerging Technologies |
Risk Factor 5: Affiliation with Entities on US Restricted Lists |
Co-authorship Considered | Time Period Reviewed |
|---|---|---|---|---|---|---|---|
Dept. of War (DoW)1
Department of War |
Prohibited: If indicators of active participation in a Malign Foreign Talent Recruitment Program (MFTRP).Within the past 5 years: Mitigation required: if indicators of participation in MFTRP by covered individual OR Mitigation required: if co-authors in publications are participants in MFTRP |
Within the past 5 years: Mitigation required: if indicators that covered individuals received funding from a Foreign Country of Concern (FCOC) (China, Russia, N. Korea, Iran) or Foreign Entity of Concern (defined in sec. 10638 (3) of the CHIPS and Science Act of 2022) |
Within the past 5 years: Mitigation required: if patent applications or patents that resulted from research funded by US Govt. were filed in a FCOC, or on behalf of an FCOC-connected entity prior to filing in USOR Mitigation required: if patents/ applications not disclosed in proposal that resulted from research funded by the US Govt are filed in a non-FCOC prior to filing in the US or filed on behalf of a non-FCOC-connected entity OR Mitigation required: if patent or co-patent applications with an individual affiliated with any entity on the version at the time of review of any Prohibited Entity Lists.5 |
Not explicitly mentioned | Prohibited: if active collaborations for the specific purpose of fundamental research between a covered individual and any academic institution or entity, or employee of such entity, on the current (at time of review) Prohibited Entity List5
OR Prohibited: if funding of or to an entity on any Prohibited Entity List5 Within the past 5 years: OR Mitigation required if covered individuals’ co-authors are affiliated with an entity on any Prohibited Entity List5 at the time of review. |
Yes, Risk Factors 1 and 5 | Past 5 years for Mitigation Required categories. Prohibited categories require active participation. |
Dept. of Energy (DoE)2
Department of Energy |
Prohibited: If indicators of active participation in a Malign Foreign Talent Recruitment Program (MFTRP). |
Certain foreign funding sources (both monetary and in-kind) | Certain concerning behaviors associated with patenting (e.g. transferring to foreign entities after filing) | If the risk indicators are present on a proposed or existing project, consideration is given to whether the project falls within a critical and emerging technology area, whether the project will have physical or cyber access to critical infrastructure, and any project work with proximity to a military installation. The same type of risk indicator can therefore warrant a different mitigation outcome, depending on the specific technology area and project. | Ties to foreign entities or foreign collaborators on specified lists or with specified characteristics. For example, U.S. Bureau of Industry and Security Entity List; Annex A of Executive Order (EO) 14032 or superseding EOs; Section 1260H of the National Defense Authorization Act (NDAA) for FY2021; Lists Published in Response to Section 1286 of the NDAA for FY2019 as amended. | Yes, Risk Factor 5 | No hard date – for activities before 2019, consideration is given to whether the activity was an isolated incident. DOE may request confirmation that the relationship has ceased. For past affiliations, associations or collaborations with entities on specified lists, DOE will consider the date the entity was added to the lists as part of the risk assessment |
National Science Foundation (NSF)3
National Science Foundation |
Prohibited: Active participation in Malign Foreign Talent Programs are prohibited | NSF will look at nondisclosure of funding sources of research, as well as nondisclosure of foreign appointments or positions | N/A | Key/critical technologies identified in the CHIPS and Science Act, beginning with Quantum Information, and potential for foreseeable national security applications of the research. | Active appointments and positions with US proscribed parties: 1. BIS Entity List, 2. the Annex of Executive Order (EO) 14032 or superseding EOs, 3. section 1260H of the FY19 NDAA or 4. section 1286 of the FY19 NDAA | No | NSF will not look at past participation in MFTRP or past positions held. Undisclosed information will be examined from January 2022 (date of issuance of NSPM-33 implementation guidance) |
National Institutes of Health (NIH)4
National Institutes of Health |
Prohibited: If indicators of active participation in a Malign Foreign Talent Recruitment ProgramMitigation Recommended: if within the past 5 years indicators of past participation in MFTRP OR Mitigation Recommended: if indicators of undisclosed or incompletely disclosed active (ongoing) participation in a MFTRP |
Mitigation Required: if there are indicators of undisclosed or incompletely disclosed active (ongoing) funding/affiliation from a Foreign Country of Concern (FCOC) or an FCOC-connected entity.
Mitigation Recommended: if within the past 5 years, indicators of undisclosed or incompletely disclosed past funding from a FCOC or a FCOC-connected entity OR Mitigation Recommended: if within the past 5 years, indicators of undisclosed or incompletely disclosed active (ongoing) funding from a FCOC or a FCOC-connected entity |
N/A | N/A | Mitigation Required: if indicators of an undisclosed or incompletely disclosed active (ongoing) affiliation with an institution or entity located in or connected with a FCOC. | No, if not related to NIH-funded work.
If related to NIH funded work, it will be considered. |
Prohibited activities require active participation.
Past 5 years for Mitigation Recommended categories. |
- 2026 Department of War (DoW) Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions March 9, 2026
- DOE Research, Technology, and Economic Security Framework for Financial Assistance and Loan Activities (RTES) November 26, 2024
- NSF Trusted Research Using Safeguards and Transparency (TRUST) June 5, 2024
- NIH Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel August 15, 2024
- DOW “Prohibited entity list” includes:
- The list published pursuant to section 1286 of the NDAA for FY 2019, as amended, or to any employees of such institutions (commonly known as the “DoW 1286 List”), published at https://basicresearch.defense.gov/Programs/Academic-Research-Security/ ;
- The list published in the Federal Register by the Department of War of Chinese military companies (CMC) operating in the United States pursuant to section 1260H of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (10 U.S.C. 113 note) (commonly known as the “DoW 1260H list” or the “1260H CMC List”), published at https://www.federalregister.gov/, search 1260H;
- The list of specially designated nationals (SDN) and blocked persons maintained by the Office of Foreign Assets Control of the Department of the Treasury (commonly known as the ‘‘SDN list’’), published at https://sanctionssearch.ofac.treas.gov/ ;
- The Non-SDN Chinese Military-Industrial Complex Companies List maintained by the Office of Foreign Assets Control of the Department of the Treasury, published at https://www.treasury.gov/ofac/downloads/ccmc/nscmiclist.pdf ;
- The Entity List maintained by the Bureau of Industry and Security of the Department of Commerce and set forth in Supplement No. 4 to part 744 of title 15, Code of Federal Regulations, published at https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C/part-744#Supplement-No.-4-to-Part-744 ;
- The Military End-User List maintained by the Department of Commerce and set forth in Supplement No. 7 to part 744 of the Export Administration Regulations (EAR), published at https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C/part-744/appendix-Supplement%20No.%207%20to%20Part%20744;
- The Denied Persons List maintained by the Bureau of Industry and Security of the Department of Commerce and described in section 764.3(a)(2) of the EAR, published at https://www.bis.gov/licensing/end-user-guidance/denied-persons-list-dpl;
- The Debarred Parties List maintained by the Directorate of Defense Trade Controls of the Department of State, published at https://deccspmddtc.servicenowservices.com/ddtc_public?id=ddtc_kb_article_page&sys_id=c22d1833dbb8d300d0a370131f9619f0 ;
- The list of telecommunications companies of the People’s Republic of China designated under section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Public Law 115– 232; 41 U.S.C. note prec. 3901) as posing national security risks to the United States, published at https://www.congress.gov/115/bills/hr5515/BILLS-115hr5515enr.pdf ;
- The list of semiconductor companies of the People’s Republic of China and affiliates designated under section 5949 of the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (Public Law 117–263; 41 USC 4713 note) as posing national security risks to the United States, published at https://www.congress.gov/bill/117th-congress/house-bill/7776/text ;
- The list maintained by the Federal Communications Commission of equipment and services covered by section 2 of the Secure and Trusted Communications Networks Act of 2019 (commonly referred to as the FCC Covered List), published at https://www.fcc.gov/supplychain/coveredlist;
- The list maintained by the Department of Homeland Security pursuant to the Uyghur Forced Labor Prevention Act (Public Law 117-78), published at https://www.dhs.gov/uflpa-entity-list; or
- The Annex to Executive Order (EO) 14032, “Addressing the Threat from Securities Investments That Finance Certain Companies of the
- People’s Republic of China,” dated 3 Jun 2021, or superseding EOs, published at https://ofac.treasury.gov/media/99111/download?inline.
Risk Mitigation Plans
If a federal agency finds risk indicators, they may request that the Principal Investigator and the University negotiate a Risk Mitigation Plan. Alternatively, a Risk Mitigation Plan may be imposed by the terms and conditions of the award. Although risk mitigation measures vary, a Risk Mitigation Plan may include:
- Research Security Training.
- Prior notification of international travel. This may include personal travel and travel not related to the award if to a Foreign Country of Concern (Russia, N. Korea, Iran, and China, including Hong Kong and Macau).
- Concurrence from the sponsor of planned international collaborations or co-authorships related to the award.
- Discontinuation of certain international collaborations for the duration of the award.
- Termination of certain affiliations or associations.
- Reporting of suspicious inquiries related to the award.
If you receive notification that risk mitigation may be required, please contact your grants administrator and the Office of Research Security at ressec@bu.edu.
Co-authorships: Foreign Collaboration/Foreign Component?
Publication with foreign co-authors is one indication of a foreign collaboration, which may trigger a review of a current proposal for research security risks (DoW) or may require pre-approval as a foreign component (NIH).
The March 9, 2026 DoW Decision Matrix requires risk mitigation of a proposal before it if:
- Within the past 5 years, a covered individual’s co-authors on publications are participants in a Malign Foreign Talent Recruitment Program; or if
- A covered individual’s co-authors on publications are affiliated with an entity on any Prohibited Entity List (DoW’s Prohibited Entity List can be found here on page 2) at the time of review.
This means that if within the past five years you have co-authored a paper with someone that is currently on a Prohibited Entity List at the time of review (which may be a DoW review of a new proposal or an annual spot check of an existing award that is presently under a Risk Mitigation Plan), you will be flagged for Risk Mitigation even if that person was not on any Prohibited List at the time of publication.
NIH defines a “foreign component” as the performance of any significant element or segment of the project outside the United States either by the grantee or by a researcher employed by a foreign institution, whether or not grant funds are expended. Activities that would meet this definition include “collaborations with investigators at a foreign site anticipated to result in co-authorship.”
Increasingly, NIH is taking a broad view of circumstances under which co-authorship constitutes a foreign component requiring pre-approval. On May 27, 2026, NIH issued NOT-OD-26-084, which states that although NIH has increased its oversight of foreign collaborations, it has not expanded its definition of foreign components. The notice provides:
Most instances of co-authorship represent a foreign component (emphasis added).The NIH recognizes, however, 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. In addition, 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.
NIH further reminds the research community:
To support full transparency and acknowledgement of federal funding, recipients are reminded of the Stevens amendment requirements outlined in the NIH GPS 4.2.1. 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 (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). In general, NIH programs do not have a legislative requirement for cost sharing. Any cost sharing requirements will be outlined in the NOFO (notice of funding opportunity).
BU Best Practices for Co-authorship
- Know your collaborators.
- Reach out to the Office of Research Security to conduct Restricted Party Screenings (RPS) on potential collaborators. While a RPS can only determine restricted status at the time of screening, it may help to prevent collaborations with entities or individuals already appearing on government lists.
- Be familiar with the BU guidelines for authorship.
- Be precise when acknowledging funding and affiliations.
- Grants should only be cited if the grant directly supported the work described in the paper and the work described in the paper is within the scope of the grant.
- Specify which authors are supported by which grants, especially if your co-authors are supported by foreign funding.
- If you are supported by foreign funding, fully disclose your foreign funding in your Current and Pending (Other) Support.
- If your foreign funding relates to a federal award, get prior approval for any foreign component.
- Increasingly, the situation arises where a student/postdoctoral scholar/visiting scholar has conducted all of the work described in a paper while at BU, but returns to or accepts employment at a foreign university before publication is finalized. In that situation, if all of the work was conducted at BU, the student/postdoctoral scholar/visiting scholar should cite only their BU affiliation and not their current, foreign affiliation.