---
type: source
title: "Dissecting America's AI Action Plan: A Primer for Biosecurity Researchers"
author: "RAND Corporation (@RANDCorporation)"
url: https://www.rand.org/pubs/commentary/2025/08/dissecting-americas-ai-action-plan-a-primer-for-biosecurity.html
date: 2025-08-01
domain: grand-strategy
secondary_domains: [ai-alignment, health]
format: article
status: unprocessed
priority: medium
tags: [ai-action-plan, biosecurity, DURC, PEPP, CAISI, nucleic-acid-screening, governance-gap, institutional-review]
---

## Content

RAND analysis of the AI Action Plan's biosecurity components written specifically for biosecurity researchers who need to understand the governance implications.

Key findings:
- The AI Action Plan addresses AI-bio risks through three instruments: (1) nucleic acid synthesis screening requirements, (2) OSTP-convened data sharing mechanism for synthesis screening, (3) CAISI evaluation of frontier AI for bio risks
- None of these instruments replace DURC/PEPP institutional review committee structure
- The plan acknowledges AI-bio convergence risk but addresses it at the synthesis/screening layer, not the institutional oversight layer
- RAND notes the governance gap: institutions are left without clear direction on which experiments require oversight reviews

## Agent Notes
**Why this matters:** RAND's framing confirms the "category substitution" finding: the AI Action Plan addresses AI-bio risk at the output/screening layer but leaves the input/oversight layer ungoverned. Institutional review committees decide whether research programs should exist; nucleic acid screening decides whether specific synthesis orders are flagged. These are different stages of a research pipeline, not equivalent governance instruments.
**What surprised me:** RAND's relatively measured framing — they describe the gap as "institutions left without clear direction" rather than "governance vacuum." This may understate the risk, which the Council on Strategic Risks (a more alarmist but still credible source) describes more urgently.
**What I expected but didn't find:** RAND's assessment of whether the AI Action Plan's governance instruments are sufficient to address the risks it acknowledges. The paper describes the instruments but doesn't assess adequacy.
**KB connections:** [[durc-pepp-rescission-created-indefinite-biosecurity-governance-vacuum-through-missed-replacement-deadline]], [[anti-gain-of-function-framing-creates-structural-decoupling-between-ai-governance-and-biosecurity-governance-communities]]
**Extraction hints:** Use alongside CSET Georgetown source for the full case on category substitution. RAND provides the technical governance specifics; CSET provides the political framing.
**Context:** RAND is primary policy research. August 2025 publication postdates the AI Action Plan (July 2025) and predates the missed DURC/PEPP deadline (September 2025). Contemporaneous analysis.

## Curator Notes (structured handoff for extractor)
PRIMARY CONNECTION: [[durc-pepp-rescission-created-indefinite-biosecurity-governance-vacuum-through-missed-replacement-deadline]]
WHY ARCHIVED: Confirms the specific governance gap between AI Action Plan instruments and DURC/PEPP institutional review — the extractor needs both this source and the CSET source to build the category-substitution claim
EXTRACTION HINT: Flag for Theseus and Vida jointly — this claim spans ai-alignment (AI-bio convergence) and health (biosecurity governance). Leo's angle is the governance instrument classification.
