DoD 2025 Decision Matrix Update

The Department of Defense (DoD) has published the 2025 Decision Matrix to Inform Fundamental Research Risk Decisions. These updates will be effective for all proposals submitted on or after May 9, 2025. These include the removal of the requirement for institutions to have a policy prohibiting participation in a malign foreign talent recruitment program (researchers are still prohibited from participation in such a program by statute, only the institution policy piece has been removed.) DoD added a prohibition included in Section 238 of the FY 2025 NDAA: “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 FY 2019, as amended, or employees of such institutions.” The updated matrix also changes some of the dates that would trigger expected or suggested mitigation measures and removes the distinction between “associations” and “affiliations.” Finally, the language of the matrix has been clarified as to the treatment of co-authorships with institutions on various entity lists or with persons in malign foreign talent recruitment programs. 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. As noted in the matrix, international collaboration is an important mechanism for participating in the global scientific commons and promoting progress in fundamental research. View the most recent matrix here.