In July, the National Science Foundation sent out a Dear Colleague Letter with a title that left little room for interpretation: “Prohibition on Collaborations with Restricted Entities.” The agency announced that its money could no longer fund research involving any organization on US restricted party lists, a category that sweeps in many of China’s largest civilian universities. Mitigation plans, the kind universities have spent years building compliance offices to produce, will no longer count. The relationship itself is the violation.
A new Quincy Institute policy note by Denis Simon, “From Disclosure to Prohibition: The Expanding US Research-Security Regime, 2020-26,” traces how the United States has arrived at this point and argues that it has taken a wrong turn. Simon, a senior research fellow in the institute’s East Asia program, doesn’t dispute that the underlying concerns are real. Undisclosed foreign appointments, hidden funding, participation in talent recruitment programs, and the diversion of sensitive technology all warrant a response, and he describes much of the early effort as necessary and overdue. His objection is to the direction of travel.
The system was never designed as one framework. Simon describes it as an accumulation of defense bills, presidential directives, and agency rules. Section 1286 of the fiscal year 2019 National Defense Authorization Act instructed the Pentagon to identify foreign institutions and recruitment programs tied to foreign militaries. The following year’s NDAA created an interagency research-security working group under the White House Office of Science and Technology Policy. The fiscal year 2021 NDAA imposed government-wide disclosure requirements on applicants for federal awards and restricted Defense Department and NSF funding to campuses hosting Confucius Institutes. Presidential Proclamation 10043, issued in May 2020, pushed the concept into immigration policy by barring certain Chinese graduate students and researchers connected to institutions associated with Beijing’s military-civil fusion strategy.
National Security Presidential Memorandum 33, issued in January 2021, attempted to pull those strands into a single framework of standardized disclosure, consequences for nondisclosure, and institutional security programs. Even the CHIPS and Science Act of 2022, which barred federally funded researchers from joining malign foreign talent recruitment programs, explicitly carved out open and reciprocal scientific exchange. Through all of it, Simon writes, the operating logic has remained disclosure and assessment: identify the foreign relationship, make it transparent, weigh the risk, and mitigate where needed.
That has changed in 2026. After the NSF letter came an August directive from the Department of War ordering research-security audits at 30 academic institutions, including reviews of ties to entities on the Section 1286 list and to organizations linked to rebranded Confucius Institutes. Most sweeping of all is a rule the Office of Management and Budget proposed this spring, which seeks to impose a categorical ban on federal funding for academic collaboration with entities owned or controlled by the Chinese government or affiliated with its military. Simon notes that those definitions are drawn broadly enough to effectively capture every leading research university in China.
He identifies three costs. The first is overcompliance: universities facing ambiguous definitions, multiple watchlists, and the threat of losing federal grants have every incentive to sever contacts with China wholesale, including in fields that pose little security risk. The second is the loss of what international collaboration offers American science, from students and visiting scholars to data, facilities, and networks. Faculty who conclude that such work has become legally uncertain or professionally dangerous will take it elsewhere. The third is competitive. China, Simon explains, has risen to global scientific leadership in multiple fields and is actively seeking a larger role in the international networks the US once dominated. Forced decoupling could deny China access to American capabilities, but it could equally cut US researchers off from the frontier and push Beijing toward deeper partnerships with other countries.
Simon’s alternative is a risk-based hierarchy, which earlier Quincy work has labeled smart openness. At the top, in fields of highest national security concern, strict restrictions and outright bans are justified. Below that, ongoing assessment could manage identifiable risks while interaction continues. Fundamental research posing little direct danger deserves a strong presumption of openness. He points out that the administration’s own 2026 National Security Science and Technology Strategy, published in August, reads far closer to that model than to a blanket ban, calling for tailored vetting, monitoring, and field-specific safeguards without recommending an end to US-China scientific contact.
The note closes by urging Congress and the White House to abandon the one-size-fits-all approach embodied in the NSF letter and the OMB proposal. The goal, Simon argues, is “neither unrestricted openness nor blanket denial” but disciplined risk management: prohibit what must be prohibited, protect what demonstrably needs protection, and preserve the far larger body of international collaboration that serves American interests.
