NIH Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel

August 2024. Assists agency staff in assessing grant applications and ongoing awards for potential foreign interference. Factors considered include: (1) current or past participation in a malign foreign talent recruitment program, which is prohibited by law, (2) undisclosed current or prior funding from a foreign country of concern (FCOC), or connected entity (currently China, Russia, North Korea, and Iran (higher risk)) or other foreign country (lower risk) and, (3) Indicators of an undisclosed current or past affiliation with an institution or entity located in or connected to a FCOC (higher-risk/mitigation) or foreign country (lower-risk/mitigation). Per the matrix, mitigation is either required, recommended, suggested, or not required based on the timing of the engagement and if accurate and complete disclosure information was provided. Mitigation conditions include: (1) specific award conditions, (2) modification of terms and conditions of award, (3) suspension, termination, or withdrawal of an award, (4) conversion from advance payment to reimbursement, and (5) recovery of funds.