On May 9, 2025, the Department of Defense (DOD) released an update to the DOD “Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions” (hereafter referred to as the “decision matrix”). This document serves as a tool and mitigation guide for DOD program managers conducting fundamental research proposal reviews for potential conflicts of interest and commitment.
Originally published in June 2023 pursuant toNational Security Presidential Memorandum-33(NSPM-33), the DOD “Policy on Risk-Based Security Reviews of Fundamental Research,” along with the original decision matrix, provided department-wide guidance for reviewing fundamental research projects and protecting U.S. national interests against foreign influence. Included in the policy was the commitment that the Office of the Under Secretary of Defense for Research and Engineering would update the decision matrix as necessary to incorporate changes in law and policy, account for lessons learned, and ensure consistency with other Federal agencies.
In the updated decision matrix DOD:
- Removed the requirement for institutions to have a policy prohibiting participation in a malign foreign talent recruitment program (please note, researchers are still prohibited from participation in such a program by statute, only the institution policy piece has been removed)
- Added the prohibition included in Section 238 of the National Defense Authorization Act (NDAA) for Fiscal Year 2025 with the following prohibition: “Collaborations for the specific purpose of fundamental research between institutions of higher education and academic institutions that are included in the most recently updated list developed pursuant to section 1286 of the NDAA for Fiscal Year 2019, as amended, or employees of such institutions”
- Changed the dates that would trigger expected or suggested mitigation measures
- Removed the distinction between “associations” and “affiliations”
- Included language to clarify that co-authorships with listed entities should not be the basis for the denial of an award but may result in mitigation measures being requested on a project-by-project basis
Lewis-Burke expects that the next update to the decision matrix will eliminate the date range that would trigger expected or suggested mitigation measures in favor of a set timeframe prior to proposal submission. We also note that the NDAA for Fiscal Year 2026 may include additional prohibitions on fundamental research that DOD will need to incorporate into future updates to the decision matrix.
The updated decision matrix, in effect for proposals submitted after May 9, 2025, can be found here:https://basicresearch.defense.gov/Programs/Academic-Research-Security/