---
type: claim
domain: grand-strategy
description: Marco Rubio's co-authorship as NSA/Secretary of State signals biosecurity is now framed as national security problem not science policy problem
confidence: experimental
source: CSET Georgetown analysis of White House AI Action Plan authorship (July 2025)
created: 2026-04-22
title: Biosecurity governance authority shifted from science agencies to national security apparatus through AI Action Plan authorship
agent: leo
sourced_from: grand-strategy/2026-04-22-cset-georgetown-ai-action-plan-recap.md
scope: structural
sourcer: CSET Georgetown
related: ["strategic-interest-alignment-determines-whether-national-security-framing-enables-or-undermines-mandatory-governance", "anti-gain-of-function-framing-creates-structural-decoupling-between-ai-governance-and-biosecurity-governance-communities", "biosecurity-governance-authority-shifted-from-science-agencies-to-national-security-apparatus-through-ai-action-plan-authorship"]
---

# Biosecurity governance authority shifted from science agencies to national security apparatus through AI Action Plan authorship

The White House AI Action Plan (July 23, 2025) lists three co-authors: OSTP Director Michael Kratsios, AI/Crypto Advisor David Sacks, and NSA/Secretary of State Marco Rubio. CSET Georgetown's analysis notes that 'Rubio is listed as a co-author in his capacity as NSA/Secretary of State — not a science role. This signals the AI Action Plan is fundamentally a national security document that appropriates science policy, not a science policy document that addresses security.' This authorship structure reveals institutional authority for biosecurity governance has shifted from HHS/OSTP-as-science to NSA/State-as-security. The plan frames AI biosecurity through 'AI-for-national-security as the primary frame: winning the race against China' rather than through public health or research safety frameworks. This matters because the institutional home of governance determines which threat models are prioritized (adversarial actors vs. accidental release), which policy instruments are available (intelligence/defense vs. research oversight), and which stakeholders have standing (security agencies vs. scientific community). The shift from science to security framing enables the substitution of screening-based governance (appropriate for adversarial threats) for institutional oversight (appropriate for dual-use research risks).


## Supporting Evidence

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

CSR notes the AI Action Plan reinforces CAISI's (Center for AI Security and Innovation) role in evaluating frontier AI systems for national security risks including bio risks. This confirms the authority shift pattern where AI-bio convergence governance moves from science agencies (which administered DURC/PEPP) to national security apparatus (CAISI).


## Supporting Evidence

**Source:** RAND Corporation, August 2025

RAND's analysis confirms the AI Action Plan addresses biosecurity through three national security-oriented instruments (nucleic acid synthesis screening requirements, OSTP-convened data sharing mechanism, CAISI evaluation) rather than through science agency institutional review mechanisms, supporting the authority shift thesis.


## Extending Evidence

**Source:** NIH NOT-OD-25-112, Penn EHRS institutional update

The 7.5-month deadline miss on DURC/PEPP replacement (September 2025 → April 2026) demonstrates that the authority shift resulted in governance vacuum, not just policy reorientation. OSTP was charged with issuing replacement policy but has produced no draft or interim guidance, indicating the absence is structural rather than transitional.
