IRP Research Security

The policies, best practices, and regulations listed below help the intramural community promote research integrity. This is not an exhaustive list of all policies and requirements that may apply to any NIH-supported research project. This list can serve as a guide for the research community.

NIH Intramural Research Program (IRP) Research Security Policies

Scientific integrity is the adherence to professional practices, ethical behavior, and the principles of honesty and objectivity when conducting, managing, using the results of, and communicating about science and scientific activities. Collaboration, transparency, and protection from inappropriate influence are hallmarks of scientific integrity. Some foreign governments seek to exploit the open international research environment, at the expense of the U.S. and its allies. In upholding the principles of scientific integrity, the IRP is committed to facilitating and maintaining productive and collaborative relationships with foreign scientists and institutions while protecting the U.S. from exploitative relationships.

Research security refers to safeguarding the research enterprise against the misappropriation of research and development to the detriment of national or economic security, related violations of research integrity, and foreign government interference. NIH established a number of policies and procedures to promote research security. The NIH values collaborations and interactions between NIH staff and foreign scientists and institutions, and the following institutional research security policies are intended to empower NIH scientific staff to engage in appropriate collaborations, not to dissuade them from such activities.

Intramural Policies and Procedures to Promote Research Security

• Guide for NIH Intramural Principal Investigators to Navigate International Interactions and Avoid Inappropriate Foreign Interference with Their Research. This guide provides information about inviting a foreign scientist to work in an NIH IRP laboratory; establishing, overseeing, or advising on research programs in foreign countries; writing professional letters of reference for foreign scientists; and establishing collaborations with foreign scientists. Additionally, investigators should consider NIH Ethics Program guidance on writing a Letter in Support of Visa Actions.
• Disclosure of external affiliations and collaborations. Intramural researchers who serve as a Principal Investigator (PI) on Z01 intramural research projects are required to submit an Annual Report for each project, which includes reporting an Annual Bibliography, a list of external collaborators, and any external professional affiliations.
• Dual-Use Research of Concern (DURC) and Pathogens with Enhanced Pandemic Potential: This guide defines “Dual Use Research of Concern and pathogens with pandemic potential,” provides information about DURC education, DURC project oversight for intramural researchers, and the IRP manuscript clearance processes for research manuscripts containing potential DURC research.
• Data Sharing Policy: These policies instruct intramural research projects to comply with the NIH Policies for Scientific Data Sharing, including the requirement for intramural NIH-funded research that generates large-scale genomic data to comply with the NIH Genomic Data-Sharing Policies governing broad, secure, and responsible sharing of human and non-human genomic data.
• Policy on the Ordering or Provision of Synthetic Nucleic Acids or Equipment in the IRP: This policy instructs IRP researchers serving as customers of providers to only order synthetic nucleic acids or benchtop nucleic acids synthesizing equipment from approved manufacturers, to mitigate the biosafety and biosecurity risks of potential misuse of synthetic nucleic acids.
• Export Control [NIH Only]: The policy, described in Manual Chapter 1340-1, governs “Permits for the Import, Transfer, or Export of Biological Materials,” to provide for the safe and secure transport of hazardous materials and comply with Federal and international regulations.
• IRP Technology Transfer Policy & Information: This website provides NIH staff with policies and guidance on patents, licenses, Cooperative Research and Development Agreements (CRADAs), Material Transfer Agreements (MTAs), and other agreements.
• NIH Visiting Program: This website describes the NIH Visiting Program, an intramural program that is open to foreign national scientists who are invited to conduct research and/or training at NIH on a temporary basis.
• Telework for IRTA/CRTA and Visiting Fellows: NIH fellows are prohibited from teleworking from international locations, or taking Government Furnished Equipment to international locations. Contact OITE for additional information.

NIH-Wide Policies and Procedures to Promote Research Security

• NIH Counterintelligence and Inside Threat Policy [NIH Only]: The policy, described in Manual Chapter 1141, establishes the NIH Counterintelligence/Insider Threat Program, to develop and implement initiatives to detect, identify, and mitigate foreign government interference, counterintelligence, and insider threats to the NIH.
• NIH Campus Access: This website provides information about gaining physical access to the NIH, including the requirement for pre-registration for non-U.S. person visitors (any individual who is not a U.S. citizen or lawful permanent resident [Green Card holder] and who does not possess an unexpired NIH-issued Department of Health and Human Services [HHS] identification [ID] badge).
• NIH Official Duties and Outside Activity Approvals [NIH Only]: This website explains the institutional oversight of NIH staff engaging in “outside activity,” whether through approval of Official Duty Activities or approval of outside activities that are not part of one’s official duties; these policies also govern official duties and outside activity with foreign entities.
• NIH Sponsored Travel Policy, Foreign Travel [Under Development, NIH Only]: Manual Chapter 1500 describes NIH travel policies and procedures, including international and sponsored travel; this policy has been rescinded but is currently being revised.
• NIH Cybersecurity - Office of the Chief Information Officer [NIH Only]: This website provides information for NIH staff on the NIH Information Security Program, including policies and standards such as NIH Information Security Policy Handbook, and NIH IT General Rules of Behavior, which provides direction to NIH and the Institutes Centers and Offices (ICOs) for appropriate use of NIH information systems and resources.
• Coordination of International Activities [NIH Only]: This policy, described in Manual Chapter 1895, explains the responsibilities of the John E. Fogarty International Center (FIC), through its Division of International Relations, to coordinate international activities on behalf of the NIH in cooperation with NIH ICOs. ICOs are strongly urged to engage FIC prior to engaging in international activities.
• NIH Office of Logistics and Acquisition Operations (OLAO): OLAO supports quality acquisition and logistics support, including overseeing compliance with the “Make PPE in America Act” and the HHS Enterprise Supply Chain Risk Management Program. 
• US Treasury - Committee on Foreign Investments in the US “CFIUS”: CFIUS is a federal interagency committee authorized to review certain transactions involving foreign investment in the US and certain real estate transactions by foreign persons; HHS and NIH engage with CFIUS as appropriate.

NIH staff with questions about IRP Research Security may contact CDR Alfredo Sancho, IRP Research Security Coordinator, at alfredo.sancho@nih.gov or AIRIO@od.nih.gov.