Research Security

Department of Energy Foreign National Approval


In accordance with the March 2nd, 2022 update to Department of Energy Order DOE 0 142.3B (Chg 1) foreign nationals participating in DoE contracts, financial agreements, and other DoE agreements who require access to DoE sites, information, or technologies must file for DoE approval as required in the Contractor Requirement Document (CRD). Foreign national approval documentation includes a Curriculum Vitae (CV) with no lapses in time over the past 10 years, and other information specified in the Order’s CRD.

How UGA Handles Approval Requests

New DOE funding opportunities (e.g. grants, cooperative agreements contracts) may include these updated Orders going forward. Existing awards would have to be modified to specifically apply the Orders to ongoing work. Principal Investigators may have different requirements to follow on their various DoE awards because each DoE Office and DoE Lab may enforce DoE Order 142.3B in a different way. As defined by DoE, anyone who is not a U.S. citizen by birth of naturalization is a foreign national.

Due to the complications these restrictions may impose on faculty, staff, graduate students, and undergraduate students, ORSEC reviews all DOE funding opportunities and modifications to existing agreements for applicability of the Order. Sponsored Projects Administration and ORSEC will assist individuals in submitting the required approvals and provide guidance as necessary to comply. No research team members should submit the required approvals themselves. Foreign nationals cannot participate while an approval request is pending review.

There is always a risk that UGA may need to decline or terminate an award if DoE does not approve a foreign national’s participation on the project. ORSEC and Sponsored Projects Administration will therefore work to remove or modify the foreign national access clause whenever possible.

PIs are advised to include a statement in the Scope of Work indicating that the proposed project will be “fundamental research.” ORSEC can assist in drafting this language if it is anticipated that the scope should not be subject to dissemination or participation restrictions.

Note: Any member of the research team that receives a request for citizenship or nationality information at the proposal, award, or post award stages should notify SPA and ORSEC.