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                                                                                        Updated March  10, 2025

Global Pandemics: Gain-of-Function Research of Concern


Gain-of-function (GOF) research is a broad area of
scientific inquiry that examines how and why an organism
gains a new property or an existing property is altered. The
terms gain offunction and loss offunction refer to any
genetic mutation in an organism that, respectively, confers a
new or enhanced ability or causes the loss of an ability.
Such changes often occur naturally. Additionally, scientists
can induce some changes to organisms through
experimentation.

A key area of GOF research is the study of both naturally
occurring and experimentally induced changes in organisms
to better understand the transmission, infectious properties,
and pathogenesis of viruses. Some argue that GOF research
may improve understanding of human-pathogen
interactions, aid in assessments of potential pandemic
pathogens, and further public health preparedness. Others
have raised concerns that studies designed to understand
how viruses might evolve may generate pathogens that
affect humans and have the potential to cause a pandemic.

To focus attention on this small subset of studies that
involve GOF-type research, the scientific and policy
communities use terms such as GOF research of concern
(GOFROC);   enhanced potential pandemic pathogens; and
most recently, pathogens with enhanced pandemic potential
(PEPPs). However, these terms have, and can be, used
interchangeably in some public discussions and media.

Risks  and   Benefits
Scientists and the public have debated the risks and benefits
of GOF research, which also has been of interest to
Congress. Some in the scientific community argue that this
research is needed to better understand how viruses evolve
and to develop better medical countermeasures and
surveillance regimes for emerging pathogens. Further, they
assert that this research can be conducted responsibly with
proper biosafety and security protocols. Others argue that
the risks outweigh any potential benefits and that alternative
experiments should be considered. Multiple federal policies
and guidelines govern the funding and oversight of life
sciences research broadly, which includes GOF research
(see Table 1). These require certain biosafety and
biosecurity protocols to be implemented at the institutions
where the research is to be conducted. These policies and
guidelines do not currently apply to GOF research.

History of Oversght Mechanisms
Concerns over GOF research emerged in 2011-2012 around
a set of studies funded by the National Institutes of Health
(NIH) on respiratory transmission of the highly pathogenic
avian influenza virus H5N1. At that time, the debate
centered on the security risks of publishing the results of
these studies and whether the research should have been


allowed to proceed, considering the risk of accidental
release. These debates, along with a series of government
laboratory biosafety incidents not associated with the H5N1
studies, led the White House Office of Science and
Technology Policy (OSTP) to issue U.S. Government Gain-
of-Function Deliberative Process and Research Funding
Pause on Selected Gain-of-Function Research Involving
Influenza, MERS, and SARS Viruses in October 2014. This
initial pause affected 18 federally funded research projects
and contracts; 7 of them subsequently received exemptions
from the pause.

As part of the 2014 pause, OSTP initiated a deliberative
process to evaluate the potential risks and benefits of GOF
research with potential pandemic pathogens. In January
2017, OSTP  released Recommended Policy Guidancefor
Departmental Development ofReview Mechanismsfor
Potential Pandemic Pathogen Care and Oversight (P3CO),
which described attributes of federal agency review and
reporting processes for the additional oversight of federally
funded research that would be anticipated to create,
transfer, or use enhanced pathogens with pandemic
potential. Agency implementation of a review and reporting
process with the described attributes would allow an agency
to support certain types of GOF research.

Following the OSTP guidance, the Department of Health
and Human  Services (HHS) released Frameworkfor
Guiding Funding Decisions About Proposed Research
Involving Enhanced Potential Pandemic Pathogens (HHS
P3CO  Framework)  in December 2017. Consequently, the
issuance of the HHS P3CO Framework  excused HHS from
the 2014 GOF research pause. HHS was the only agency
that developed a GOF review process in response to the
2017 OSTP  GOF  guidance and the only federal agency that
has reported GOF research funding.

COVID-19 and GOF
The emergence of COVID-19  and debates on its origin
have refocused attention on GOF and particularly the NIH
funding of the EcoHealth Alliance study Understanding the
Risk of Bat Coronavirus Emergence, in which scientists
from the United States and the Wuhan Institute of Virology
collaborated. Some have argued that this project should
have been captured by the 2014 pause on GOF research and
reviewed under the HHS P3CO  guidance. In testimony to
the House Select Committee on the Coronavirus Pandemic,
NIH  reportedly concluded that the research project did not
meet the criteria of the 2014 pause on GOF research or the
2017 HHS  P3CO  guidance.


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