Department of Defense (Department of War) Updated Risk Matrix for Fundamental Research

Overview

On March 9, 2026, the U.S. Department of Defense (DoD)/ Department of War (DoW) published an updated “Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions” (“Decision Matrix”) that provides review criteria in support of the DoD/DoW’s January 7, 2026 Memorandum titled “Fundamental Research Security Initiatives and Implementation.”

The new Decision Matrix provides criteria that impact eligibility for federal funding, such as certain international collaborations and co-authorships, as well as use of equipment from certain prohibited organizations on DoD/DoW awards.

MSU faculty may be impacted if:

A faculty member has collaborated or published with entities on (a now expanded group of) U.S. restricted lists,

A faculty member has equipment from an organization on one of the U.S. restricted lists that is used in their DoD/DoW funded research, or

A faculty member has participated in a Malign Foreign Talent Recruitment Program (MFTRP), has received funding from a Foreign Country of Concern (FCOC), or has engaged in certain patent filing activities (described in further detail under “Decision Matrix Categories” below).

DoD/DoW fundamental research proposals can now be flagged for review, require mitigation, or be denied funding based on these factors. MSU faculty who have DoD/DoW funding, or plan to apply, should review the Decision Matrix carefully, as it outlines new compliance requirements that could affect proposals and future awards.

Background

The DoD/DoW issued the first decision matrix in June 2023 and has updated the matrix annually. Recent updates impact how proposals are assessed and what equipment that can be used on funded projects. The changes to the Decision Matrix will be effective within 60 days of the March 9, 2026 release date.

The 2026 Decision Matrix states:

“Funds appropriated for the DoW may not be used for grants, contracts, other transactions or other assistance to an institution of higher education if the purpose is to conduct fundamental research in collaboration with, or using equipment from, any entity named on any of the ‘Prohibited Entity Lists... This funding prohibition also extends to the employees of such institutions.” 

“Prohibited Entity Lists” now refers to a compilation of thirteen U.S. Government (USG) lists, included on page two of the Decision Matrix, which is a significant increase from the four lists previously included. Note, the prohibition on equipment from restricted entities is at the project level, which means that equipment from sources included on the Prohibited Entity Lists may not be used on DoD/DoW projects.

Decision Matrix Risk Categories

In the 2026 Decision Matrix, the four types risk factors remain the same, while the prohibitions have broadened, and include the following:

Foreign Talent Recruitment Programs: Covered Individuals (Senior Key Personnel) who participate in Malign Foreign Talent Recruitment Programs (MFTRP) are prohibited from receiving DoD/DoW funding

Funding Sources: Mitigation is required if Covered Individuals (Senior Key Personnel) received funding in the last five years from a Foreign Country of Concern (FCOC). FCOC’s are defined as China (including Hong Kong and Macau), Russia, North Korea and Iran.

Patents: Patent applications resulting from U.S. government-funded research that were first filed in a Foreign Country of Concern (FCOC) or with an individual affiliated with an entity on the Prohibited Entity Lists will have mitigation measures required.

Entity Lists: Active collaboration for the specific purpose of fundamental research (that is identified in the DoD/DoW fundamental research project proposal) between a Covered Individual and any academic institution or entity, or employee of such entity, on the current Prohibited Entity Lists is prohibited.

Special Note: Co-authoring Publications

There are additional risk factors in the Decision Matrix related to co-authoring publications that will require mitigation measures, including: 

Within the past five years, if a Covered Individual’s co-author(s) on publications in scientific and engineering journals are either: 1) participants in a Malign Foreign Talent Recruitment Program (MFTRP) or 2) are affiliated with an entity on any of the Prohibited Entity Lists at the time of review, there will be mitigation measures required by DoD/DoW.

Best Practices for co-authorship and grant citations in publications include:

Performance of significant elements of a U.S. Government-funded project outside the U.S. must be disclosed and approved by the funding agency in advance.

When citing a grant in a publication, link the grant to the appropriate author (e.g., “D.E.F. was funded by NIH grant AI123456”).

If an MSU student, postdoctoral scholar, or visiting scholar has subsequently moved to another institution, cite the (home/grantee) institution where the work was conducted and not the current affiliation of the co-author. Otherwise, if the current affiliation is on a Prohibited Entity List,this will require risk mitigation measures by DoD/DoW.

If work is being conducted at another institution, that must be cited. If work is conducted outside the country, it must be approved in advance by DoD/DoW.

Guidance for MSU faculty

Do not participate in a Malign Foreign Talent Recruitment Program (MFTRP) if you plan to continue to accept federal funding. If you are unsure whether an opportunity qualifies as a talent program, contact the MSU’s Research Security Program (researchsecurity@msu.edu) for assistance.

Provide full and accurate disclosures in all required documents (e.g., Biosketch, Other Support, proposal disclosures, and project updates) with MSU’s Office of Sponsored Programs.

Run Restricted Party Screening to verify whether any collaborators, coauthors, institutions, or companies appear on Prohibited Entity Lists. Contact MSU’s Research Security Program (researchsecurity@msu.edu) for assistance with screening.

For U.S. government–funded research:  Do not file patent applications in non-U.S. jurisdictions before filing in the U.S. Ensure all related intellectual property is fully disclosed to MSU.

Ensure that any equipment you plan to use is not sourced from an entity on a Prohibited Entity List. MSU’s Research Security Program (researchsecurity@msu.edu) can conduct screenings to confirm equipment providers are not restricted parties.

Ask questions early and often. If something is unclear, or if you think an issue might be a concern, please contact MSU’s Research Security Program (researchsecurity@msu.edu) for guidance.