Members of our research community should take note of several federal policy announcements released this summer (2026) covering a range of topics, including co-authorship, travel, foreign talent recruitment programs, international research collaborations, data safeguarding, AI use, and other areas of research compliance.
 

Report Foreign Co-Authorship

Researchers receiving National Institutes of Health (NIH) funding should promptly disclose any foreign co-authorship to the appropriate NIH Institute or Center once it becomes known. Timely reporting allows NIH to assess whether additional review or action is required.

Faculty are also encouraged to ensure that NIH-funded publications accurately acknowledge the federal awards that supported the work and do not cite grants that were not associated with the research. In addition, investigators should carefully review the requirements outlined in the applicable Notice of Funding Opportunity (NOFO), as certain NIH programs prohibit foreign components or collaborations.

For questions contact your Research Foundation Sponsored Programs Grants & Contracts Administrator (GCA) or reach out to rfawards@odu.edu. 

 

Consult the Office of Research Security Before Entering Foreign Collaborations

The U.S. Department of Defense has released an updated identified as engaging in activities that may increase the risk of unauthorized technology transfer and other research security concerns.

Faculty and researchers involved in international collaborations, proposal development, sponsored research, or other research-related engagements with foreign institutions are encouraged to review the list and consult with the Office of Research Security & Export Control before initiating or expanding such activities. Early consultation can help ensure compliance with federal requirements and sponsor expectations.

The updated list includes academic and research institutions in countries of concern, including China, Russia, and Iran. Additional details are available in the Department of Defense's and the accompanying list of identified institutions:

For questions or guidance regarding international collaborations and research security requirements, contact the Office of Research Security & Export Control at researchsecurity@odu.edu.

 

Reminder: Participation in Malign Foreign Talent Recruitment Programs Is Prohibited

Federal research security requirements prohibit participation in The U.S. Department of Energy has reiterated these restrictions as part of its research security guidance and communications.

Faculty and research personnel should carefully evaluate any foreign appointment, affiliation, consulting arrangement, talent recruitment program, sponsored position, laboratory appointment, or similar opportunity before accepting or continuing participation. Certain foreign programs may create conflicts with federal research security requirements and could affect eligibility for federally funded research.

Researchers are encouraged to consult the Office of Research Security & Export Control before entering into any foreign affiliation or agreement that may raise research security concerns. Early review can help identify potential compliance issues and ensure adherence to sponsor requirements.

Questions regarding foreign affiliations, appointments, talent recruitment programs, or related research security requirements should be directed to the Office of Research Security & Export Control at researchsecurity@odu.edu.

 

Avoid Carrying Sensitive Information During International Travel

Faculty, staff, and students traveling internationally should be aware of evolving security, privacy, and legal requirements that may affect electronic devices and data. Recent guidance from the U.S. Consulate General in Hong Kong notes that individuals entering or transiting through Hong Kong, including U.S. citizens, may be subject to legal requirements involving access to electronic devices, including requests for passwords or decryption assistance.

To reduce risk, travelers should avoid carrying unnecessary sensitive, proprietary, export-controlled, or restricted information on laptops, mobile phones, tablets, and other electronic devices. When possible, use loaner devices, store data securely through approved university resources, and limit access to university systems and information to what is necessary for the trip.

Faculty, staff, and students planning international travel involving research activities, university data, export-controlled information, or other sensitive materials are encouraged to consult the b before departure. Early planning can help ensure compliance with university policies, sponsor requirements, and applicable laws and regulations.

Additional information is available through the U.S. Consulate General Hong Kong security alert:

  • Security Alert: Changes to Hong Kong National Security Law Implementation Rules

 

For guidance on international travel, research security, or safeguarding university information abroad, contact the Office of Research Security & Export Control at researchsecurity@odu.edu.

 

Safeguard Research Data, Intellectual Property, and Technology

Federal research security officials continue to emphasize the importance of protecting research data, intellectual property, and emerging technologies from unauthorized access or transfer. A joint federal publication, Safeguarding Our Data, Intellectual Property, and Technology from Non-Traditional Collectors, highlights how foreign governments may seek access to valuable U.S. research and technology through individuals such as academics, students, researchers, business professionals, or technology specialists acting as "non-traditional collectors."

The publication notes that these individuals may not have direct ties to a foreign intelligence service but may still acquire sensitive information, proprietary technology, research data, or intellectual property in support of another country's economic, scientific, military, or strategic objectives.

Researchers and research administrators should take proactive steps to protect sensitive information by:

  • Limiting access to research data and information systems on a need-to-know basis.
  • Using strong passwords, multi-factor authentication, and encryption to safeguard data.
  • Conducting appropriate due diligence when granting access to sensitive research activities.
  • Following university guidance for device security, data storage, and international travel.

  • Reporting suspicious requests, activities, or security concerns through established university channels.

     

Additional guidance is available in the federal publication:

  • Safeguarding Our Data, Intellectual Property, and Technology from Non-Traditional Collectors

 

For questions about research security, data protection, intellectual property safeguards, or international research risks, contact the Office of Research Security & Export Control at researchsecurity@odu.edu.

 

NIH Updates Data Management and Sharing Plan Requirements

The National Institutes of Health (NIH) has released Notice NOT-OD-26-046, which updates the required format and content of Data Management and Sharing (DMS) Plans. The revised approach is designed to simplify plan preparation and review by replacing lengthy narrative descriptions with a more structured format.

Under the updated requirements, investigators will respond to a series of standardized questions addressing key topics such as data sharing intentions, timelines for sharing, data availability, protections for human participant data, and genomic data sharing requirements when applicable. The new format also includes space to explain any limitations on data sharing and a concise table identifying anticipated data types and the repositories that will be used to preserve and share data.

Researchers preparing NIH proposals should familiarize themselves with these changes to ensure their DMS Plans align with current NIH expectations and support responsible data stewardship throughout the research lifecycle.

Additional information is available through the NIH notice:

  • NIH Notice NOT-OD-26-046: Updated Elements of an NIH Data Management and Sharing Plan

 

Faculty and staff seeking assistance with Data Management and Sharing Plans are encouraged to consult available university research support resources at the University Libraries, , Nikki Galloway at ngallowa@odu.edu or your Research Foundation Sponsored Programs Grants & Contracts Administrator (GCA). 

 

Verify Institutional Review Board (IRB) Approval

The National Institutes of Health (NIH) recently issued Notice NOT-OD-26-043: Reminder of Requirement for Certification of IRB Approval, reaffirming that certification of Institutional Review Board (IRB) approval is required for all non-exempt human subjects research as part of the Just-in-Time (JIT) process. Pending, conditional, interim, or expired IRB approvals do not satisfy this requirement.

The notice also emphasizes that NIH funds may not be used to conduct non-exempt human subjects research without current IRB approval. Although NIH may issue an award before IRB certification has been received, any resulting award will include restrictions that prohibit human subjects research activities until the required IRB documentation has been submitted and accepted by NIH.

Researchers should ensure IRB approvals remain current and that all required certifications are provided in a timely manner to avoid delays in project implementation and compliance issues.

Additional information is available in the NIH notice:

  • NIH Notice NOT-OD-26-043: Reminder of Requirement for Certification of IRB Approval

     

For questions regarding human subjects research, IRB review, or protocol approvals, contact the Institutional Review Board (IRB) at irb@odu.edu.

 

Use Artificial Intelligence (AI) Safely and Responsibly

As artificial intelligence (AI) tools become increasingly integrated into research activities, investigators should remain mindful of their responsibilities for the accuracy, integrity, and confidentiality of all research-related work. In its article, Helpful Reminders to Ensure Integrity of NIH-Supported Research When Using Artificial Intelligence, the National Institutes of Health (NIH) emphasizes that researchers remain accountable for all content, analyses, and decisions associated with NIH-funded research, regardless of whether AI tools are used in the process.

NIH notes that AI tools may be appropriate for limited administrative or drafting support in certain circumstances; however, researchers should carefully evaluate AI-generated content for accuracy, completeness, bias, and compliance with sponsor requirements. Investigators should also take steps to protect sensitive, proprietary, confidential, or human subjects data and should avoid entering restricted information into publicly available AI platforms unless authorized by institutional policy.

Importantly, NIH states that applications that are substantially developed by AI, or that contain sections substantially generated by AI rather than reflecting the original ideas and scientific contributions of the applicant, may not be considered for funding. Researchers are therefore encouraged to use AI as a supporting tool rather than a substitute for their own scholarly and scientific work.

Additional guidance is available from NIH:

  • Helpful Reminders to Ensure Integrity of NIH-Supported Research When Using Artificial Intelligence

 

Reminder: Certain Agreements Require Institutional Review

Faculty and research personnel who receive a Data Use Agreement (DUA), Data Access Agreement, Non-Disclosure Agreement (NDA), Material Transfer Agreement (MTA), Confidentiality Agreement, or similar document from an external organization should not sign, accept, or act upon the agreement independently. These agreements can create legal, regulatory, data security, privacy, export control, intellectual property, or sponsor-compliance obligations for the University, even when the activity appears routine or a research project is already underway.

Before data, materials, or proprietary information are shared or accessed, these agreements must be reviewed and approved through the appropriate university process. Agreements requiring institutional authorization may only be executed by an individual with delegated signature authority on behalf of the University.

Depending on the nature of the agreement, additional review may be required to address data security, privacy, export controls, controlled research requirements, intellectual property considerations, or secure computing needs.

Researchers should contact the Research Foundation Sponsored Programs Office before:

  • Accepting or acting on a DUA, NDA, MTA, or similar agreement.
  • Downloading, receiving, or accessing restricted or controlled data.
  • Storing, sharing, transferring, or analyzing data provided by an external organization.
  • Receiving research materials, proprietary information, or controlled technologies from outside entities.
  • Committing the University to any terms, conditions, or obligations related to research activities.

Questions regarding external research agreements, data access, sponsored projects, or compliance requirements should be directed to the Research Foundation Sponsored Programs at rfawards@odu.edu.  

 

NIH Announces New Oversight Framework for High-Risk Life Sciences Research

The National Institutes of Health (NIH) has announced a new federal policy designed to strengthen oversight of life sciences research that may pose significant risks to public health, public safety, economic security, or national security. Issued pursuant to Executive Order 14292, the policy establishes a new framework for identifying and overseeing certain categories of high-risk biological research.

The framework identifies two broad categories of research requiring heightened scrutiny:

  • Dangerous Gain-of-Function (DGOF) Research, involving biological agents where the research seeks, achieves, or presents a substantial risk of achieving outcomes that could result in significant negative societal consequences.
  • International Research of Concern (IROC), which includes certain research conducted in countries of concern, by individuals or institutions of concern, or in locations where adequate research oversight may not exist. 

The new policy replaces the previous federal framework governing Dual Use Research of Concern (DURC) and Pathogens with Enhanced Pandemic Potential (PEPP) and will eventually become the primary oversight mechanism for these higher-risk life sciences research activities.

Researchers should be aware that the policy has been issued, but agency-specific implementation guidance is still under development. Federal agencies have been directed to develop and publish implementation guidance, and NIH has indicated that additional information and oversight requirements will be released in the coming months. As a result, many of the specific investigator and institutional compliance requirements associated with the new framework are not yet fully implemented. 

One notable exception is that NIH has stated that research activities previously identified as potential DGOF research under earlier NIH notices will remain paused until NIH-specific implementation requirements are established. 

Additional information is available at:

  • NIH Notice NOT-OD-26-101: U.S. Government Policy for Stopping High-Risk Life Sciences Research
  • Executive Order 14292: Improving the Safety and Security of Biological Research

 

Researchers with questions about the potential applicability of these requirements to their work are encouraged to contact the Research Foundation Sponsored Programs at rfawards@odu.edu.  Additional guidance will be shared with the research community as federal agencies release implementation requirements.