Letter from APS leadership

APS Fundamental Research Risk Assessment Matrix

December 22, 2023

The Honorable Heidi Shyu
Office of the Under Secretary of Defense, Research and Engineering (OUSD(R&E))
3030 Defense Pentagon, Washington, DC 20301-3030

Dear Under Secretary Shyu:

On behalf of the more than 50,000 members of the American Physical
Society (APS) – the largest physics membership organization in the United States – I am writing to extend our appreciation for your office’s efforts in developing the new guidance and policies on risk-based security reviews of fundamental research, as outlined in your June 8, 2023 memorandum titled “Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education.”

APS supports the Department of Defense’s (DOD’s) thoughtful approach
to developing and implementing risk-based research security reviews of
fundamental research. As you know, fundamental research benefits from
remaining open to the maximum extent possible, and while there is a need to consider security, overly-broad security policies have the potential to chill international collaboration, punish honest mistakes, and cause longterm damage to the U.S. scientific enterprise. The value international collaborations provide to the United States is clear, but we also recognize that there are legitimate concerns with unwanted foreign influence.

We support the new policy’s emphasis on risk mitigation, which we believe is a productive process for lowering risk within the basic research
environment. In particular, we appreciate DOD publicly providing its
decision matrix for reviewing potential conflicts of interest and conflicts of commitment in fundamental research proposals. This step greatly improves transparency and provides our community a better understanding of how their research proposals may be reviewed. Allowing fundamental research proposals to be evaluated for whether risks can be mitigated, rather than simply being rejected for any level of security risk, prevents the potential immediate rejection of promising scientific work due only to potential research security concerns.

Instituting policies that require making risk-based assessments — instead of relying on nondiscerning filters — is an essential step towards appropriately balancing research security risks and the research requirements for open science. As you review and refine the new guidelines, we ask that you and your staff work to continue strengthening these policies by considering a few key issues outlined below.

We are concerned with the possibility of reputational risk to our members, and researchers broadly, when a research proposal is flagged for mitigation. If a proposal is rejected under mitigating measures, this may result in a stigma associated with the principal investigator’s work. Such a stigma could impede a researcher’s future applications for funding, formation of collaborations, or other aspects vital to carrying out their research program. This concern extends to concern of reputational harm by association, if current work with a student or close collaborator is found to be unacceptable under the new guidelines. Safeguards to ensure that mitigating measures do not prevent a researcher from pursuing acceptable work or collaborations in the future should be developed and implemented.

To ensure the most effective implementation of the guidelines, we suggest a robust feedback mechanism to relay input from the research community. Through two-way communication, we can create a more secure fundamental research environment that both protects our national
interests and allows for the international collaboration crucial to driving innovation. Additionally, an assessment of the overall impact of the policy on the U.S. research enterprise should be carried out after three years. This assessment will help determine if the new policies are appropriately balancing research openness and security risks.

Finally, to enable a widespread understanding of DOD’s new policies in the physics community, we urge you to explore avenues for sharing the information widely and offering educational materials for Principal Investigators to better understand what is or is not considered a risk. We
are happy to assist with any outreach efforts to the physics community.

Thank you again for your leadership in working to ensure the United States remains a global leader in science, technology, and innovation. We also hope that the other federal science agencies will follow DOD’s example and implement similar, transparent, risk-based measures, such that a more uniform approach to research security is taken by all federal science agencies. If you have questions or would like to further discuss our concerns outlined above, please do not hesitate to contact APS Director of Public Affairs Mark Elsesser (; 202.846.8121).


Robert Rosner

PresidentAmerican Physical Society


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