PolicyBrief
S. 854
119th CongressJul 30th 2025
Risky Research Review Act
AWAITING SENATE

The Risky Research Review Act establishes the Life Sciences Research Security Board to review and approve federal funding for high-risk life sciences research that could potentially harm public health or national security.

Rand Paul
R

Rand Paul

Senator

KY

LEGISLATION

New Biosecurity Board Gets Binding Authority to Halt Federal Funding for 'High-Risk' Research

The newly proposed Risky Research Review Act is setting up a major, independent oversight body called the Life Sciences Research Security Board. This Board’s job is simple but powerful: review and issue a final, binding decision on whether federal agencies can fund any research categorized as “High-Risk Life Sciences Research.” Think of it as a mandatory, high-stakes security check before the money for sensitive science can leave the bank.

What Exactly Is “High-Risk” Science?

This is where the bill gets specific, defining “High-Risk Life Sciences Research” as anything that falls into two main categories: Dual Use Research of Concern (DURC) involving a High-Consequence Pathogen OR Gain of Function Research (SEC. 2). In plain English, this means experiments that could easily be misused to cause serious harm (DURC), or research designed to make a dangerous germ more contagious or deadly (Gain of Function). The list of pathogens covered is extensive—everything from certain influenza strains to Ebola and coronaviruses—and the Board can vote to add more categories later. This broad scope gives the new Board significant power over the direction of federally funded biology.

The New Gatekeepers of Science

The Life Sciences Research Security Board will have nine members, appointed by the President, serving up to two four-year terms. Crucially, the bill mandates that this group must be composed primarily of non-government scientists and national security experts. To keep things clean, the bill imposes strict conflict-of-interest rules: Board members can’t have worked for key agencies (like Defense, Homeland Security, or NIAID) for three years prior, and any member who has participated in high-risk research must have their potential conflicts scrutinized by the Office of Government Ethics (OGE) (SEC. 2). This is a strong move intended to ensure that the people deciding what science gets funded are impartial and not beholden to the agencies they oversee.

The Real-World Impact on Researchers and Funding

Starting 180 days after this law passes, the funding landscape changes immediately. Agencies cannot award money for high-risk research without the Board’s explicit approval. If you’re a researcher applying for a grant, you now have to attest, under penalty of perjury, whether your proposed work is high-risk (SEC. 2). If you lie, you face referral for suspension or debarment from future federal funding. If your research is deemed high-risk, the agency must send your proposal to the Board, which then has up to 120 days to review it and decide if the funding can proceed. For researchers, especially those working on fast-moving infectious diseases, a 120-day pause could be a major delay, potentially slowing down vital work. If your research suddenly becomes high-risk mid-project, you have to stop work within 24 hours and notify the agency within five days. While the bill includes an expedited 15-day review process for national security or public health emergencies, the default is a lengthy review, which is where many in the scientific community might feel the pinch.

Power and Oversight

This bill centralizes control over sensitive life sciences research in a way we haven't seen before. The Board’s decision is final and binding. When reviewing a proposal, the Board must weigh the potential threats to public health and national security against the potential benefits, and it must also consider whether lower-risk methods could achieve the same results (SEC. 2). This balancing act is subjective, and the Board’s authority to audit previously funded research adds another layer of continuous oversight. While the goal is necessary biosecurity—preventing a lab accident or misuse of dangerous technology—the practical challenge lies in managing this new, powerful layer of bureaucracy without unduly stifling important, cutting-edge science.