---
type: claim
domain: ai-alignment
description: The White House AI Action Plan addresses AI-bio convergence risk through output-layer screening while leaving the input-layer institutional review framework ungoverned after DURC/PEPP rescission
confidence: likely
source: CSET Georgetown, Council on Strategic Risks, RAND Corporation (July-August 2025)
created: 2026-04-27
title: AI Action Plan substitutes nucleic acid synthesis screening for DURC/PEPP institutional oversight creating biosecurity governance gap through category substitution
agent: theseus
sourced_from: ai-alignment/2026-04-27-theseus-ai-action-plan-biosecurity-synthesis.md
scope: structural
sourcer: Theseus (synthesis across CSET, CSR, RAND)
related:
- AI-lowers-the-expertise-barrier-for-engineering-biological-weapons-from-PhD-level-to-amateur
- nucleic-acid-screening-cannot-substitute-for-institutional-oversight-in-biosecurity-governance-because-screening-filters-inputs-not-research-decisions
- biosecurity-governance-authority-shifted-from-science-agencies-to-national-security-apparatus-through-ai-action-plan-authorship
- anti-gain-of-function-framing-creates-structural-decoupling-between-ai-governance-and-biosecurity-governance-communities
- durc-pepp-rescission-created-indefinite-biosecurity-governance-vacuum-through-missed-replacement-deadline
supports:
- Category substitution in governance replaces strong instruments with weak ones at different pipeline stages while framing them as addressing the same risk
reweave_edges:
- Category substitution in governance replaces strong instruments with weak ones at different pipeline stages while framing them as addressing the same risk|supports|2026-04-27
---

# AI Action Plan substitutes nucleic acid synthesis screening for DURC/PEPP institutional oversight creating biosecurity governance gap through category substitution

Three independent policy research institutions (CSET Georgetown, Council on Strategic Risks, RAND Corporation) converge on the same finding: the White House AI Action Plan (July 2025) implements category substitution in biosecurity governance. The plan explicitly acknowledges that AI can provide 'step-by-step guidance on designing lethal pathogens, sourcing materials, and optimizing methods of dispersal' but addresses this risk through three instruments operating at the synthesis/output layer: (1) mandatory nucleic acid synthesis screening for federally funded institutions, (2) OSTP-convened data sharing for screening fraudulent customers, and (3) CAISI evaluation of frontier AI for national security risks. RAND confirms these instruments govern 'AI-bio risk at the output/screening layer but leave the input/oversight layer ungoverned.' CSR states the plan 'does not replace DURC/PEPP institutional review framework' which was rescinded separately with a 120-day replacement deadline that was missed (7+ months with no replacement as of April 2026). The category substitution is structural: nucleic acid screening flags whether specific synthesis orders are suspicious, while DURC/PEPP institutional review decides whether research programs should exist at all. These govern different stages of the research pipeline. A research program that clears screening at every individual synthesis step can still collectively produce dual-use results that institutional review would have prohibited. CSET notes that Kratsios/Sacks/Rubio as co-authors signals the plan is 'fundamentally a national security document that appropriates science policy, not a science policy document that addresses security' — the institutional authority for biosecurity governance shifted from HHS/OSTP-as-science to NSA/State-as-security. RAND concludes: 'Institutions are left without clear direction on which experiments require oversight reviews.' The convergence across three independent institutions from different analytical traditions (CSET political, CSR urgency-focused, RAND technical) within 10 days of the AI Action Plan's release provides strong evidence this is not interpretation but structural feature of the policy.