Understanding the Research Security Review Process

Research security reviews help the U.S. Government preserve an open and collaborative research environment based on principles of transparency, accountability, fairness, and reciprocity. Research security reviews are designed to protect Federally funded R&D from foreign interference and exploitation, which is often at the expense of U.S. innovators and U.S. economic and national security.

About ARPA-H's Research Security Program

The Advanced Research Projects Agency for Health (ARPA-H) Research Security Program is a risk-based security review process of proposals submitted in response to agency solicitations for funding. The ARPA-H Research Security Program deploys a balanced approach to evaluate proposing institutions and covered individual behaviors that may be contrary to federal policy, law, and guidance; undermine the integrity of ARPA-H-funded research; and/or introduce risk to the agency’s research programs and U.S research enterprise.

Who goes through a research security review

All proposals recommended for funding following submission to the agency’s research programs, projects, and initiatives go through a research security review. The exceptions are proposals submitted through the Small Business Innovative Research (SBIR) and Small Business Technology Transfer (STTR), which follow a separate process through the NIH.

ARPA-H requires all senior/key personnel or covered individuals, as defined in NSPM-33*, to list on their biographical sketch:

• All their professional preparations (including but not limited to their undergraduate and graduate degrees)
• All their current and past appointments and positions (including but not limited to guest, honorary, and adjunct professorships and talent program participation, whether full-time, part-time, or voluntary.)

ARPA-H also requires senior/key personnel to list on the current/pending support form all sources of current and pending support, and to attest that they are not part of a malign foreign talent recruitment program, as defined by the OSTP Foreign Talent Recruitment Program Guidelines (Feb. 2024). Instructions for the submission requirements can be found in ARPA-H’s National Security and Policy Attachment template and in active solicitations located on Sam.gov and Grants.gov.

SBIR/STTR due diligence reviews are currently covered by the National Institutes of Health (NIH)- Small Business Education and Entrepreneurial Development (SEED) office and therefore do not need to go through a separate process.

What you need to know

Research security reviews will be:

• Conducted separately from the agency’s scientific and merit review process.
• Conducted only on proposals that are recommended for funding.
• Handled in parallel with other award negotiations, including requests for clarification or additional documentation from proposers.

Incomplete information or lack of responsiveness can result in removal from negotiation and halt of award.

What this process looks like

Step 1: As part of preparing your materials to submit a full proposal, you will complete the “Administrative & National Policy” Attachment, which is available at the solicitation notice.

Step 2: Submit your materials with complete, accurate information.

Step 3: If your proposal is selected for potential funding and proceeds to negotiation of Award, the research security review process will begin. ARPA-H will identify any research security risks for further clarification and mitigation. 

Step 4: You may be contacted with further instructions, request for clarification, or with a request to propose mitigation measures. ARPA-H requires proposers who receive research security-based questions to respond directly and fully to all questions within requested timelines.

Step 5: ARPA-H will make a determination of whether the agency can satisfactorily mitigate any research security risks and if any remaining risk (if applicable) can be accepted. You will be notified of intent or inability to continue toward Award.

Additional Resources

The following are publicly available resources regarding research security/countering undue foreign influence education and mitigation examples. The list is not exhaustive and does not imply any specific endorsement by ARPA-H. All resources link externally and open in a new window.

• National Security Presidential Memorandum 33 (NSPM-33)
• Office of Science and Technology Policy NSPM-33 Implementation Guidance
• Office of Science and Technology Policy NSPM-33 Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs
• The CHIPS and Science Act of 2022
• Office of the Director of National Intelligence resources
• National Science Foundation Research Security Training
• Office of Science and Technology Policy, Guidelines for Research Security Programs at Covered Institutions, July 9, 2024

*A covered individual is an individual who contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a federal research agency and is designated as a covered individual by the federal research agency. Covered individuals include personnel identified on a proposal as “senior/key personnel,” such as the principal investigator(s), co-principial investigator(s), researcher(s), and consultant(s). If the proposing institution is a company, covered individuals may also include key management personnel, owners, and investors. 

Still have questions?

If you are in the middle of applying to a solicitation, please direct your specific questions to your Agreements Officer and/or email provided on the solicitation.

For general inquiries, please contact ResearchSecurity@arpa-h.gov.