On July 20, 2026, the Federal Government issued the United States Government (USG) Policy for Stopping High-Risk Life Sciences Research which replaces the 2024 USG Policy for Oversight of Dual Use of Concern and Pathogens with Enhanced Pandemic Potential, also known as the DURC-PEPP policy. COGR's Stopping Policy Infographic highlights the policy differences and institutional changes required to implement the new policy.
The new policy states that federal funding agencies will provide implementation guidance within 120 days of this policy issuance (i.e., November 2026), and institutions receiving any federal life sciences funding must begin implementation within 180 days of this policy issuance (i.e., January 2027).
Further information on University of Virginia implementation measures related to the new policy will be available soon.
Dangerous Gain of Function Research (DGOFR)
DGOFR is research with a “biological agent” (essentially ANY microorganism, biotoxin or infectious agent) that seeks, achieves, or has a substantial risk of achieving one of the experimental outcomes “and could result in significant negative societal consequences”:
- Enhancing the harmful consequences of the biological agent (including creation of mirror organisms)
- Disrupting beneficial immunological response or the effectiveness of an immunization against the biological agent
- Conferring to the biological agent resistance to clinically or agriculturally useful prophylactic or therapeutic interventions against that biological agent or facilitating its ability to evade detection methodologies
- Increasing the stability, transmissibility, or ability to disseminate the biological agent
- Altering the host range or tropism of the biological agent
- Enhancing the susceptibility of a human, animal, or plant host population to the biological agent
- Generating or reconstituting an eradicated or extinct biological agent.
DGOFR is prohibited. If a PI discovers DGOFR:
- Research must immediately stop
- Reported to the Institutional Review Entity (IRE) and the institution's designated Institutional Contact for DGOF (ICDGOF)
- Notify the primary Federal Funding Agency
Non-compliance with these reporting and halting protocols can result in immediate termination or suspension of awards, revocation of federal funding, and multi-year ineligibility for future federal life sciences grants.
Potential DGOFR
Research with a biological agent “that could potentially result” in one of more DGOFR experimental outcomes and could result in “significant negative societal consequences.”
Potential DGOFR will require review by UVA’s IRE and an Independent Third-Party Review Body (ITPRB) established at the federal level.
International Research of Concern (IROC)
Research Involving Countries or Entities of Concern is life sciences research conducted in a country of concern; or research conducted outside of the U.S. by an institution or individual of concern, as specified on a list that will be developed and maintained by the USG.
Other Risky International Research is “life sciences research that could reasonably pose a threat to public health, public safety, and economic or national security conducted in a country with inadequate oversight to ensure that the country is compliant with United States oversight standards and policies” as determined by the head of the funding department/agency with support from relevant agencies.
UVA must review all federally funded life sciences research for IROC and “monitor” non-federally funding research for IROC concerns.