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Volume LVII, Number 2 |

K. Ann Bell
Virginia Commonwealth University

Abstract

The United States government is actively working on a national security framework that will balance the need to protect science and technology while maintaining an open, collaborative, and accountable research environment for scientists to conduct fundamental research in their fields. As a result of recently passed legislation, federal agencies have begun implementing a number of requirements on researchers, including personal attestations of all funding, affiliations, and in-kind support on documents submitted to federal funders using standardized forms. Institutes of higher education are typically held accountable for noncompliance by the federal government, incurring a range of administrative penalties as a result. However, with the passage of recent research security legislation and publication of federal guidance documents, the balance of liability for nondisclosures has also shifted to individual researchers. This review paper outlines the background on research security legislation, implementation of the Common Forms, history of legal cases involving foreign affiliations, and explanation of the fraud statutes and False Claim Act, with the goal of providing an overview of the current state of research security mandates in the United States. It was written to assist research administrators in understanding how these legal changes impact the research community.

Keywords: research security, law, liability, disclosures, research administration, malign foreign talent recruitment program, higher education

Introduction

Research administrators (RAs) are compliance professionals, tasked with ensuring that pre- and post- award communications, draw downs, internal controls, etc. are all managed within a research security framework and guided by state and United States (U.S.) federal statutes and regulations. Recent changes in federal policy have created headwinds for RAs at all stages of the grant lifecycle. These changes are most pronounced in relation to recent research security mandates from the federal government, including the JASON Report, National Security Presential Memorandum 33 (NSPM-33) and various policy prescriptions from federal agencies (JASON, 2019; NSPM-33, 2021). Due to the rapid and at times conflicting requirements, institutional policies are at risk in not reacting fast enough to federal changes to mitigate problematic compliance issues, and Principal Investigators (PIs) are at a higher risk of failing to disclose activities and appointments on federally mandated documents than in prior years. RAs, who are often front-line staff between their institution and faculty members, may be wondering how they are expected to balance the dynamic research security environment and still provide quality customer service and guidance to faculty members.

For RAs whose job is to ensure that PIs and other key personnel are appropriately reporting activities and outside appointments, the workflow must allow time both at the pre-award and Just In Time (JIT) stage (right before award receipt) to arrange for obtaining and submitting documentation prior to communicating with federal agencies. Ample time would ensure that all documents and assurances are “current, accurate, and complete” (National Defense Authorization Act for Fiscal Year 2021, Section 223 (a)(1)(B)). However, given the increasingly heavy workload of many RAs and PIs, the ability to manage this process can be challenging, and documents can be submitted that are inaccurate or incomplete, most often without malign intent.

Additionally, PIs are not trained to understand the legal requirements of grants and contracts before certifying and signing disclosure forms and accepting terms and conditions. Nonetheless, there has been a significant shift in legal obligations away from institutions with the implementation of federally mandated Common Forms which can be digitally accessed from Science Experts Network Curriculum Vitae (SciENcv) platform. On the Common Forms for biographical sketches or Current and Pending Support, PIs are now certifying that they (1) “are not a party to a maligned foreign talent recruitment program” (MFTRP) and (2) understand that “misrepresentations and/or omissions may be subject to prosecution and liability pursuant to, but not limited to, 18 U.S.C. §§ 287, 1001, 1031 and 31 U.S.C. §§ 3729-3733 and 3802” (National Library of Medicine, National Center for Biotechnology Information., n.d.; National Institute of Standards and Technology, 2025; U.S. Department of Justice Civil Division, 2011; see also annotated references). As a result, the burden of liability for employees’ violations of disclosure requirements has shifted to individual certifiers: the government is now mandating these certifiers acknowledge their personal liability for violating federal law. RAs should be clear on the legal ramifications for each certification section so they can provide helpful advice to PIs during grant, JIT, and post-award submissions. In response to these concerns, this paper and literature review will provide a deeper understanding of research security legal frameworks and provide guidance on how to educate PIs and other key personnel on the new requirements. Background on research security, descriptions of Common Forms, cases involving foreign influence, and statutes are explained in the following sections and in the annotated references.

Research Security and the Development of the Common Forms

The current U.S. framework for research security is outlined by the National Institutes of Standards and Technology (2023), part of the United States Department of Commerce. Research security is defined as a set of methods and procedures that are intended to protect research and development (R&D) activities from malign actors. These programs were deemed necessary after WWII at the height of U.S. scientific hegemony when concerns about illicit Soviet technology transfer became pronounced (National Security Decision Directive 189, 1985). Subsequently, malign actor concerns have focused mainly on China and to a lesser extent Russia, Iran and other countries (National Institute of Standards and Technology, 2025; Tiffert & Gamache, 2025). Specifically, China has become such a threat to R&D that Congressional reports and criminal investigations of Chinese scientists are well publicized, with notable condemnation by the Chinese scientific community (Select Committee on the Chinese Communist Party & Committee on Education and the Workforce, 2025a,b; United States Senate Committee on Homeland, Security & Governmental Affairs Permanent Subcommittee on Investigations, 2019; Xie et al., 2023). As a result of these concerns, the U.S. government has developed measures to prompt federal agencies to improve their oversight of taxpayer-funded grants and contracts. A review of recent reports and legislation related to ensuring accuracy in disclosure information is summarized below.

JASON Report (2019)

One of the first widely disseminated unclassified reports confirming malign influence on the U.S. research enterprise was the JASON Report by The MITRE Corporation, commissioned by the National Science Foundation (NSF). One of its findings, that malign foreign influence was a national security threat, prompted NSF to begin drafting policies related to both appointments and outside activities on Biosketch forms and Current and Pending Other Support documents in addition to other changes. The JASON Report noted that there were significant “problems with respect to research transparency, lack of reciprocity in collaborations and consortia, and reporting of commitments and potential conflicts of interest” by reviewing both public data and classified data (2019, p. 2). They found that malign influence fell into four categories: reward, deception, coercion and theft. Rewards are high value-laden incentives to attract and retain talent and become problematic when investigators take advantage of offers that then become a conflict of interest and/or commitment, and they also do not report the outside appointment or activities to their U.S. institution. Deception occurs when affiliations, commitments, or other educational activity are omitted or otherwise falsified on official documentation including grants, reports, and visas. Deception can lead to federal indictments under the federal fraud statutes (see below). Coercion occurs when there is an explicit or implicit threat made by the foreign actor to a person under their influence. These tactics can include coercive or restrictive foreign employment contract clauses and/or knowledge of potential negative consequences to the individual should they report their outside affiliations to their U.S. employer. Lastly, theft of intellectual property (IP) is of serious concern and can include any number of items including actual materials, software, or even ideas. As a result of this report, NSF took immediate steps to improve their oversight of the granting process, having already begun developing the standardized forms for disclosure (Córdova, 2019).

National Security Presidential Memorandum 33 (2021)

In 2021, the White House issued NSPM-33 as official government policy on national security of the research enterprise for institutions that receive more than $50 million a year in federal R&D funding. NSPM-33 focused on shoring up administrative requirements for grant seekers and others to guard against foreign influence through the use of the Common Forms, digital persistent identifiers, notice of legal consequences for violations of disclosure obligations, information sharing of cases involving disclosure violations across all agencies, and development and implementation of a research security program that covers four fundamental operations, a cybersecurity program, foreign travel security program, and training in export controls and research security (Prabhakar, 2024). Although the memorandum did not prescribe the use of SciENcv as an electronic platform for biosketches and for disclosures of other types of research support, it did expect continuity for the use of standardized forms across federal funding agencies. Many agencies are now either mandating SciENcv be used in funding applications or are still in the process of adopting its use. SciENcv Common Forms, both Biosketch and Current and Pending Support forms, requires certification from individuals that they are not a party to a MFTRP and that they understand that misrepresentations and/or omissions may be subject to prosecution. Additionally, individuals must link their ORCID, a personal digital identifier, to their SciENcv account (ORCID, n.d.). Although RAs can be named as delegates in SciENcv, they cannot certify the form on behalf of an individual. Additional guidance from the Subcommittee on Research Security Joint Committee on the Research Environment at the National Science and Technology Council (2022) elaborated on the legal consequences, administrative, civil and criminal, for disclosure violations at any stage in the grant lifecycle. The government has a range of possible sanctions against both recipient organizations and individuals depending on the specific fact pattern of the violation (National Institute of Standards and Technology, 2025; Valdez et al., 2025).

William M. Thornberry National Defense Authorization Act for Fiscal Year 2021

Further disclosure requirements were put forth in the National Defense Authorization Act for Fiscal Year 2021 (NDAA FY2021). Under this statute, agencies can refer disclosure violations to their Inspector General or law enforcement agencies for further prosecution. To shield themselves from enforcement action, institutes of higher education must therefore (a) notify the PI and other covered individuals (key personnel) listed on the application of the need for full disclosure of Current and Pending Support, (b) have no knowledge that any covered individual falsified or omitted information, and (c) not be owned, controlled or influenced by the violator who violated disclosure rules. By providing training and notification, institutions are mitigating their liability, leaving individuals to protect themselves through full and accurate disclosures on their Common Forms (Section 223 (a)(3)). 

CHIPS and Science Act (2022)

The CHIPS and Science Act, signed into law in 2022, provided a framework for $50 billion in direct investments in science and technology through Notices of Funding Opportunities for manufacturing, workforce and education. The Act provided funds for specific areas in science and technology including semiconductor manufacturing, and the programs are administered by the U.S. Department of Commerce’s National Institute of Standards and Technology (NIST). NIST was also tasked with providing reports to Congress on oversight of U.S. R&D research security, and in 2023, released NIST IR 8484, a research security framework for agencies and organizations (see annotated references). Additionally, the Act mandated that NSF maintain a Research Security and Policy office and establish an “integrity information sharing analysis organization,” that will identify foreign influence in the research enterprise, develop standard risk assessment frameworks, educate the research community about security threats and lessons learned, and provide additional training to institutes of higher education on these topics. The NSF SECURE (Safeguarding the Entire Community of the U.S. Research Ecosystem) Center, run by the University of Washington, is currently the resource that was developed to specifically address this mandate (NSF, n.d.). The Center provides regular research security briefings and updates to the research community.

Title VI, Subtitle D of the CHIPS and Science Act, “Research Security,” outlined the specific prohibitions on participation by individuals in MFTRPs. The Act mandated that individuals provide a signed attestation and that institutes of higher education provide training regarding these requirements. Some institutes of higher education have agreed that the training provided by NSF SECURE center will meet these requirements, although some universities have also created customized in-house training programs.

Under the Act, federal agencies are also authorized to request copies of translated contracts, grants, or other agreements specific to foreign appointments or employment. In the event such documentation is provided that indicates a conflict of interest/commitment, the agencies are authorized to take any number of administrative actions including removing the individual from the award, reducing the funding amount, or award suspension/termination. 

Balancing Legal Liability

Failure to comply with federal legislation, as discussed in the above sections, would provide a path for the government to directly hold institutions accountable for individuals’ disclosure violations. Furthermore, the legal doctrine of respondeat superior usually holds an employer responsible for criminal acts by employees if done within the scope of the employee’s duties. This occurs even in the face of due diligence to mitigate harm by implementing compliance programs. In fact, many corporate compliance programs are paper only programs with no real concern for effectiveness and exist only to limit damages in the event of prosecution (Luskin, 2020; Silver, 2024). However, misconduct attributed to rogue employees that does not fall within the scope of work can be prosecuted. False or fabricated certifications of disclosures like underreporting outside employment or failing to report grants from foreign funders in opposition to sponsor requirements and university policy could result in legal liability for the employee in addition to employer liability. The context and fact pattern for each disclosure violation would be analyzed to determine a likely legal outcome. The Subcommittee on Research Security and Joint Committee on the Research Environment at the National Science and Technology Council (2022) developed the NSPM-33 implementation guidance that delineated the set of factors taken into consideration by the government upon discovery of a disclosure violation. These factors include (a) harm or potential harm to the agency, the government, U.S. taxpayers, and other national interests, (b) intent by the offender, (c) individual knowledge of requirements, (d) pattern of violations if any, (e) timing of the disclosure, (f) policies, procedures and training available/required, and (g) other mitigating information. This guidance document also references NDAA FY2021 which limits institutional liability for compliant organizations.

Table 1 describes some high-profile cases of criminal charges against faculty members for disclosure violations related to Chinese employment and talent programs (National Institute of Standards and Technology, 2025; MIT Technology Review, 2021; Papadantonakis, 2024). The cases are listed to illuminate the specific charges and outcomes related to disclosure violations. The list is not intended to stereotype any one group of scientists. In fact, the instructive cases are the acquittals. For example, Anming Hu was acquitted of the false statement charge because the disclosure form was submitted more than two years prior to grant submission to the federal agency and because the knowledge of falsity standard for false statements was not met. Feng Tao’s conviction was overturned on appeal by the 10th Circuit. In a 2:1 split, the majority did not agree with the District Court that the false statement standard was met. The Court reasoned that the disclosure violation, which occurred after the grants were awarded, could not have influenced the agencies’ decisions. Most sponsored programs offices are now requiring conflict of interest disclosures prior to submission, and granting agencies are asking for Current and Pending Other Support prior to award receipt, eliminating the availability of these defenses. 

Table 1. Department of Justice China Initiative, Criminal Case Law on Disclosure Violations

Note. Some of these cases are discussed in more detail by NIST (2025), Papadantonakis (2024), Xie et al. (2023) and can also be accessed by the MIT Technology Review’s China Initiative database.

Conclusion

Research administrators are in a position to assist faculty members in understanding these new disclosure requirements through the management of the Common Forms. Educating faculty members about the legal framework for violations assists not only in organizational research security but also serves to protect faculty members from possible federal and state prosecutions. Although organizations will be required to provide some type of disclosure training by federal sponsors as part of their research security program, a once-a-year training will not replace the personal contact that faculty members have with their counterparts in research administration. Furthermore, as the Common Forms become mandated across federal agencies, organizations are in a position to share and publish their experience with the new requirements. Training programs, especially customized programs, can be shared and disseminated across the research enterprise. Institutional integration can be reported out describing successes and challenges. Finally, case reports of actual investigations would be helpful in communicating to other organizations the impact their programs may have on mitigating reporting violations. 

Author's Note

Corresponding Author

K. Ann Bell
Virginia Commonwealth University
Correspondence concerning this article should be addressed to Ann Bell.
kabell@alumni.vcu.edu

Legal Resources: Annotated References

False Claims Act and Administrative Remedies for False Claims and Statements, 31 U.S.C. §§ 3729-3733 and 3801-3802 (2026). https://uscode.house.gov/view.xhtml?path=/prelim@title31/subtitle3&edition=prelim; U.S. Department of Justice, Civil Division. (2011). The False Claims Act: A primer. https://www.justice.gov/sites/default/files/civil/legacy/2011/04/22/C-FRAUDS_FCA_Primer.pdf

            The Department of Justice describes the §3801 definition of a claim as "a demand for money or property made directly to the Federal Government or to a contractor, grantee, or other recipient if the money is to [be] spent on the government’s behalf and if the Federal Government provides any of the money demanded or if the Federal Government will reimburse the contractor or grantee." Sections 3729(a)(1)(A) and (B) of the False Claims Act (FCA) outlines liability for any person who knowingly submits a false claim to the government or causes another to submit a false claim to the government or knowingly makes a false record or statement to get a false claim paid by the government. Section 3729(a)(1)(G) is known as the reverse false claims section; it provides liability where one acts to avoid having to pay money to the government. Section 3729(a)(1)(C) creates liability for those who conspire to violate the FCA. The monetary penalties under the FCA are very steep and are calculated for each false claim plus triple the amount of the damages to the government. For instance, each invoice submitted for payment can constitute an individual claim and the cost of each claim would be tripled to calculate the damages. The FCA has mostly been used in healthcare fraud cases and against research institutes, not individual faculty members.

Criminal False Claims and Fraud, 18 U.S.C. §§ 287, 1001, 1031 (2026). https://uscode.house.gov/view.xhtml?path=/prelim@title18&edition=prelim

The federal fraud statutes listed in the certification documents are found in Title 18 of the US Code. 18 U.S.C §§287, 1031 are fraud statutes related to making false claims and major grant or contract fraud. Charges against individuals for disclosure violations involving false statements to official law enforcement officers are usually charged under 18 U.S.C §1001. Upon questioning, these individuals deny knowledge of disclosure rules or related activities or submit falsified documents. For example, individuals may deny foreign employment, remuneration, or grants awarded. Under §1001, the government must prove that the individual charged “knowingly and willfully (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact; (2) makes any materially false, fictitious, or fraudulent statement or representation; or (3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry.” The Courts have concluded that a false statement is material only if it influences a decision from a decision maker such as a federal agency (United States v. Tao, 2024).

National Institute of Standards and Technology. (2023). Safeguarding international science: Research security framework (NIST IR 8484). U.S. Department of Commerce. https://doi.org/10.6028/NIST.IR.8484

U.S. Government and regulatory agencies do not usually mandate that organizations must use a prescribed set of cybersecurity, privacy, or research security programs. Rather, this guidance document was developed by NIST to help organizations manage high risk R&D by outlining various components for an ideal research security program that can be tailored for each institute of higher education. These components include development of (1) expert research security team, (2) strategic communication and organizational integration, (3) review categories for high-risk activities and affiliations (4) review methodology and outcome determination (5) export control, technology control plans, and compliance procedures. Most institutes of higher education will have some of these elements already in place, but all will have to create formal research security programs in order to successfully compete for federal funding and avoid legal liability.

Subcommittee on Research Security Joint Committee on the Research Environment. (2022). Guidance for implementing National Security Presidential Memorandum 33 (NSPM-33) on national security strategy for United States government-supported research and development. National Science and Technology Council. https://bidenwhitehouse.archives.gov/wp-content/uploads/2022/01/010422-NSPM-33-Implementation-Guidance.pdf

This document provided further details on NSPM-33 implementation for organizations. It details the disclosures required and the consequences for disclosure violations. Core components that federal agencies should follow include (1) standardization of disclosure requirements including disclosure table, (2) use of digital persistent identifiers for disclosure processes, (3) consequences for violation of disclosure requirements (administrative, civil, criminal) under state and federal laws, (4) information sharing about disclosure violations across agencies and with the research community, and (5) development of a research security program by research institutions. It can be shared with PIs and other key personnel as a resource on required disclosures.

References

CHIPS and Science Act, Pub. L. No. 117-167, 136 Stat. 1372. (2022). https://www.congress.gov/bill/117th-congress/house-bill/4346

Córdova, F. (2019). Response to the JASON Report ‘Fundamental science and security.’ National Science Foundation. https://nsf-gov-resources.nsf.gov/files/NSF-response-JASON.pdf

False Claim Act, 31 U.S.C. §§ 3729–3733 & 3802 (2026). https://uscode.house.gov/view.xhtml?req=granuleid%3AUSC-prelim-title31-subtitle3&saved=%7CZ3JhbnVsZWlkOlVTQy1wcmVsaW0tdGl0bGUzMS1zZWN0aW9uMzcyOQ%3D%3D%7C%7C%7C0%7Cfalse%7Cprelim&edition=prelim

Federal Fraud Statutes, 18 U.S.C. §§ 287, 1001, & 1031 (2026).  https://uscode.house.gov/view.xhtml?req=granuleid%3AUSC-prelim-title18-part1&saved=%7CZ3JhbnVsZWlkOlVTQy1wcmVsaW0tdGl0bGUxOC1zZWN0aW9uMjg3%7C%7C%7C0%7Cfalse%7Cprelim&edition=prelim

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National Institute of Standards and Technology. (2023). Safeguarding international science: Research security framework (NIST IR 8484). U.S. Department of Commerce. https://doi.org/10.6028/NIST.IR.8484

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National Science Foundation. (n.d.). SECURE Center. Retrieved September 19, 2025, from https://www.secure-center.org/

National Security Decision Directive 189. (1985, September 21). National policy on the transfer of scientific, technical, and engineering information. https://irp.fas.org/offdocs/nsdd/nsdd-189.htm

National Security Presidential Memorandum-33. (2021). National security strategy for U.S. government-supported research and development. https://bidenwhitehouse.archives.gov/wp-content/uploads/2022/01/010422-NSPM-33-Implementation-Guidance.pdf

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