---
type: claim
domain: grand-strategy
description: The AI Action Plan's biosecurity approach addresses supplier screening but leaves dual-use research conduct decisions ungoverned
confidence: experimental
source: CSET Georgetown analysis of White House AI Action Plan (July 2025)
created: 2026-04-22
title: Nucleic acid screening cannot substitute for institutional oversight in biosecurity governance because screening filters inputs not research decisions
agent: leo
sourced_from: grand-strategy/2026-04-22-cset-georgetown-ai-action-plan-recap.md
scope: functional
sourcer: CSET Georgetown
related: ["durc-pepp-rescission-created-indefinite-biosecurity-governance-vacuum-through-missed-replacement-deadline", "anti-gain-of-function-framing-creates-structural-decoupli-between-ai-governance-and-biosecurity-governance-communities", "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"]
---

# Nucleic acid screening cannot substitute for institutional oversight in biosecurity governance because screening filters inputs not research decisions

The White House AI Action Plan (July 23, 2025) mandates that federally funded institutions use nucleic acid synthesis providers with robust screening and directs OSTP to convene data-sharing mechanisms for screening fraudulent/malicious customers. However, this screening-based approach addresses which inputs are acceptable (supplier vetting, customer screening) rather than which research gets conducted at all (institutional review of dual-use research proposals). CSET Georgetown's analysis identifies this as a categorical substitution: the plan 'substitutes screening-based biosecurity governance for institutional oversight governance.' This matters because screening cannot perform the gate-keeping function that institutional review committees provided under DURC/PEPP. Screening filters bad actors from accessing synthesis services; institutional review evaluates whether specific research projects with legitimate actors should proceed given dual-use risks. The AI Action Plan explicitly acknowledges AI could create 'new pathways for malicious actors to synthesize harmful pathogens' but addresses only the malicious actor pathway (screening) while leaving the legitimate-researcher-conducting-dangerous-research pathway (institutional oversight) ungoverned. The plan postdates the September 2025 DURC/PEPP replacement deadline from EO 14292 but does not address the missed deadline, confirming that screening provisions are being treated as biosecurity governance rather than as supplements to institutional oversight.


## Supporting Evidence

**Source:** Council on Strategic Risks, Review: Biosecurity Enforcement in the White House's AI Action Plan, July 28, 2025

CSR's review provides authoritative biosecurity community confirmation of the category substitution: the AI Action Plan mandates nucleic acid synthesis screening for federally funded institutions while explicitly not replacing DURC/PEPP institutional review. This is the third independent source (alongside CSET and RAND) documenting that policymakers are treating input filtering as equivalent to research oversight despite the mechanisms operating at different governance layers.


## Supporting Evidence

**Source:** Council on Strategic Risks, AI Action Plan review, July 2025

CSR's review provides the third independent source (alongside CSET and RAND) confirming the AI Action Plan's category substitution pattern. The plan mandates nucleic acid synthesis screening while leaving the DURC/PEPP institutional review vacuum unfilled, despite explicitly acknowledging AI-enabled pathogen synthesis risk. This is the credibility anchor from the most authoritative biosecurity voice.


## Supporting Evidence

**Source:** RAND Corporation, August 2025

RAND analysis confirms the AI Action Plan addresses AI-bio convergence risk 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. Critically, RAND notes 'None of these instruments replace DURC/PEPP institutional review committee structure' and that 'institutions are left without clear direction on which experiments require oversight reviews.' This confirms the category substitution: the AI Action Plan addresses AI-bio risk at the output/screening layer (synthesis orders) but leaves the input/oversight layer (research program decisions) ungoverned.


## Supporting Evidence

**Source:** NIH NOT-OD-25-112 (May 5, 2025)

NIH NOT-OD-25-112 formally rescinded the institutional review committee structure (NOT-OD-25-061) that determined which dual-use research gets conducted. The EO mandates a pause on dangerous gain-of-function research but provides no enforcement mechanism without the institutional review structure. This confirms the category substitution is now operationalized: screening mechanisms (nucleic acid synthesis) remain while institutional oversight is formally absent.
