Risky Research Review Act
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The bill would create the Life Sciences Research Security Board — a new independent federal agency with binding authority to approve or deny federal funding for high-risk life sciences research, including gain-of-function experiments and dual-use research involving dangerous pathogens such as Ebola, influenza A, and SARS- and MERS-related coronaviruses.
By requiring mandatory pre-award review, applicant attestations under penalty of perjury, and stiff penalties for noncompliance, the bill would establish the first statutory gatekeeping system for federally funded biosecurity-sensitive research, affecting every agency that funds life sciences work.
What this bill would do
What it would do
The bill would establish the Life Sciences Research Security Board as a new independent executive-branch agency with authority to review proposed federal funding for "high-risk life sciences research" — defined to include gain-of-function experiments and dual-use research of concern involving high-consequence pathogens such as Ebola, influenza A, SARS- and MERS-related coronaviruses, Marburg virus, and others. The Board's approval determinations would be binding on all federal agencies. Entities seeking federal grants or contracts would have to attest under penalty of perjury whether their proposed research is high-risk; agencies would certify those attestations and could not award funding without Board approval. The Board would complete standard reviews within 120 days and emergency reviews within 15 days. It could also retroactively review and suspend pre-enactment federally funded research it deems high-risk.
The bill would not regulate privately funded research and would not apply to research that does not involve federal money. The Board's nine presidentially appointed members — including a Senate-confirmed Executive Director, five life scientists, two national security experts, and one biosafety expert — would be subject to strict conflict-of-interest screening and security clearance requirements. The Government Accountability Office would periodically audit the Board, and the Board would report annually to Congress.
Key provisions
- 1Would establish the Life Sciences Research Security Board as an independent executive-branch agency with nine presidentially appointed members, including a Senate-confirmed Executive Director, five life scientists, two national security experts, and one biosafety expert.
- 2Would direct the Board to issue binding determinations on whether federal agencies may award funding for high-risk life sciences research, and to set minimum biosafety, biosecurity, and personnel assurance controls for approved research.
- 3Would prohibit agencies from awarding federal funding for high-risk life sciences research without Board approval, and would require funding applicants to attest under penalty of perjury whether their proposed research is high-risk.
- 4Would require entities to pause ongoing research within 24 hours and notify their funding agency within 5 days if circumstances arise that may transform the research into high-risk life sciences research.
- 5Would require the Board to review high-risk proposals within 120 days, weighing public health benefits against risks, and allow the Board to retroactively review and suspend pre-enactment federally funded research deemed high-risk.
- 6Would create an expedited 15-day review track for proposed emergency research related to a declared public health emergency or specific national security concern, with temporary funding authority if the Board misses the deadline.
- 7Would subject agency employees who knowingly fail to certify applicant attestations to disciplinary action and permanent revocation of applicable security clearances; entities that falsely attest face suspension and debarment from federal funding.
Who would be affected
Universities, research institutes, private companies, and foreign entities that apply for or receive federal grants, contracts, or cooperative agreements to conduct life sciences research involving high-consequence pathogens or gain-of-function experiments. All federal agencies that fund such research — including NIH components, the Defense Department, and others — would be legally bound by Board determinations. Federal employees who fail to certify applicant attestations properly would face disciplinary action and permanent security clearance revocation.
Why it matters
If enacted, no federal agency could fund gain-of-function or dual-use dangerous-pathogen research without pre-approval from a security-cleared, independent board — a layer of mandatory oversight that does not currently exist in statute. Researchers whose proposals the Board rejects would lose access to federal funding entirely, and applicants who falsely attest their work is not high-risk would face suspension and debarment from all future federal awards.
What would change
Changes to existing law
Amends Title 31, United States Code (subtitle V) (Sec. 2(a))
Adds a new Chapter 79 creating the Life Sciences Research Security Board and all associated review, attestation, enforcement, and funding provisions.
Amends 5 U.S.C. § 13103(f) (financial disclosure requirements) (Sec. 2(c))
Adds Board members to the list of individuals required to file public financial disclosure reports.
Agencies directed to act
Effective dates
- Prohibition on awarding funding for high-risk research without Board approval
- Board must publish review procedures in the Federal Register
- Board begins carrying out review duties under Sec. 7906
- Board review section (Sec. 7906) takes effect
- Conflicts-of-interest criteria must be established by the Board
Funding and costs
- $30,000,000
Annual appropriation to the Life Sciences Research Security Board to carry out its review and oversight functions
Congressional Budget Office estimate
CBO estimates S. 854 would cost $293 million over the 2026–2035 period in discretionary spending (subject to appropriation), with no effect on direct spending, revenues, or the deficit.
S. 854 would establish the Life Sciences Research Security Board, a new independent executive branch agency to review and approve federal funding for high-risk life sciences research involving dangerous pathogens. The bill would authorize $30 million per year to operate the board, totaling $300 million in authorized appropriations over the 2026–2035 period; CBO estimates actual outlays of $293 million over that same window. The bill has no effect on direct (mandatory) spending or revenues, and therefore no impact on the deficit. CBO identified no intergovernmental or private-sector mandates.
How implementation would work
The President would appoint Board members within 30–45 days of enactment; the Board would publish review procedures within 180 days of those appointments and begin operational reviews 270 days after enactment. Each funding agency would establish its own internal process — in consultation with the Board — for identifying high-risk proposals, certify applicant attestations, and notify the Board at least 30 days before any planned life sciences award. The Board would complete standard reviews in up to 120 days and emergency reviews in 15 days, publishing approved biosafety and biosecurity control requirements. Agencies must post their prepayment and pre-award procedures online. The GAO would audit the Board periodically, and the Board would brief Congress quarterly and report annually.
Legislative status & sources
Latest action
Placed on Senate Legislative Calendar under General Orders. Calendar No. 164.
Official CRS summary
Show the CRS summaryHide the CRS summary
This bill establishes the Life Sciences Research Security Board to oversee the award of federal funding for high-risk life sciences research. High-risk life sciences research means the study of an organism, virus, or related product that could be misapplied to pose a significant threat to the public or could enhance the transmissibility or virulence of certain high-risk pathogens (e.g., Ebola).
Specifically, the bill establishes the board as an independent agency that must review proposed high-risk life sciences research, determine whether a federal agency may award funding for the research, and determine minimum required controls for funded research. Entities that are seeking federal funding must attest to whether their research is high-risk life sciences research. Agencies must certify the validity of these attestations and submit proposed high-risk life sciences research to the board. Agencies must also notify the board of intended awards for other life sciences research for potential review.
In making its determinations, the board must consider specified factors, including whether the benefits of the research outweigh the risks. The bill prohibits agencies from awarding federal funding for high-risk life sciences research without approval of the board or for life sciences research currently under board review. The board may also review awards that were made before the bill’s enactment.
Entities that fail to properly attest to the nature of their research may lose their eligibility for funding. Additionally, agency employees who fail to comply with the bill's requirements are subject to disciplinary action.
Legislative subjects
Accounting and auditing; Advisory bodies; Biological and life sciences; Congressional oversight; Employee performance; Federal officials; Government employee pay, benefits, personnel management; Government ethics and transparency, public corruption; Government information and archives; Government studies and investigations; Health; Infectious and parasitic diseases; Public contracts and procurement; Research administration and funding