Frequently Asked Questions
As part of a growing emphasis on research security, the Department of Energy has issued changes to the Foreign National Access Program, the program that establishes requirements for access to DOE national labs by non-US employees, visitors, and others. The change has three main parts:
- Visitor Site Access: All foreign nationals visiting Lab sites must now be processed through DOE. For foreign nationals from DOE’s Sensitive Countries List (SCL), these individuals must be granted DOE approval before access is permitted – a process known as completing indices checks. View a flow chart of the changes.
- New Employee and Affiliate Appointments: All foreign national employees and affiliates from DOE’s Sensitive Countries List (SCL) must complete indices checks before their appointment start date. These can no longer be completed after the fact, as they have in the past. There are exceptions made for certain Users from SCL at User Facilities. View a flow chart of the changes.
- Hosting: Foreign National employees from certain countries on the Sensitive Countries List, referred to as “Countries of Risk”, are restricted from hosting visitors on site who are from countries on the SCL.
Key Acronyms
- FNAP = Foreign National Access Program
- SCL = DOE’s Sensitive Countries List. This list includes countries labeled as
- CoR = Countries of Risk
- SST = State Sponsors of Terrorism
- “Other Designated Countries” on the SCL
Last Updated: December 5, 2025
Who does this policy change apply to at the Lab?
| Foreign national employees from designated “Countries of Risk” (CoR) will be directly impacted by the policy change. They will be restricted from hosting visitors from any country on the Sensitive Countries List. U.S. citizens and foreign national employees not from CoR will not be impacted by the new hosting requirements in the policy. However, everyone at the Lab needs to be aware of the change to site access for foreign nationals on the SCL, as it may impact collaborations with visitors, new hires, and Users. |
Who counts as a “Foreign National”? Do Green Card holders count?
| U.S. Green Card holders, legal permanent residents, and visa holders are not naturalized U.S. Citizens; they are considered by DOE to be foreign nationals. If the individual is born in or has citizenship from a country on the Sensitive Country List, they will be impacted by this new policy. If an individual is born in a country on the SCL but has since become a naturalized U.S. citizen, they are no longer considered a foreign national and they will not be impacted by this new policy. |
What countries are on the DOE Sensitive Countries List?
| Sensitive Countries include countries labeled as “State Sponsors of Terrorism,” “Countries of Risk” and “Other Designated Countries”. All CoR are considered Sensitive Countries, but not all Sensitive Countries are CoR. A shared drive hosts the list and is available to anyone with an @lbl.gov email. Follow these steps to gain access. |
Why is this change happening now?
| The change is part of a growing emphasis by the Federal Government on research security. These measures were not unexpected and are in line with other federal efforts around national security. We understand that uncertainty is difficult. Our top priority is preserving our scientific mission and supporting our people. SES is working closely with key stakeholders inside and outside the Lab to implement the changes with as little impact to research and operations as possible. |
What do we mean by “site access”?
| Site access refers to our main Lab site as well as Potter St., JBEI, ABPDU, and any off-site excess property & storage facilities (see a list of off-site facilities here). Anyone planning to come on site or to any of these locations will need to pass indices checks beforehand if they are a foreign national from a Sensitive Country. An exception is made for foreign nationals from “Other designated countries” on the SCL under a User Agreement; indices checks can be completed after access is granted for this group. |
What is an indices check?
| Indices checks are a required component of the Department of Energy (DOE) process for screening foreign nationals for access to DOE sites. This process involves submitting a request through DOE systems to determine if any adverse or relevant security information exists about the individual. The primary objective is to verify the individual’s background and ensure their presence on-site is fully consistent with national security interests and compliance requirements. The check is formally initiated by documenting the access request in the Foreign Access Central Tracking System (FACTS). Once the indices check is complete, our local Counterintelligence (CI) Office conducts a final review and provides a formal sign-off for the individual to come on site. Indices checks for foreign nationals are not new for the Lab; the change is primarily of timing. Indices checks have historically been completed after the start date or date of site access, but must now be completed before access is granted to foreign nationals from CoR or other designated countries on the SCL. Foreign nationals from countries designated by the federal government as State Sponsors of Terrorism (SST) countries remain prohibited from site access unless they meet certain exemption criteria. |
How long do indices checks take?
| Based on guidance from our DOE partners at Lawrence Livermore National Laboratory who process our FACTS submissions, we suggest planning for 60 calendar days to allow for sufficient time for the indices checks to clear. Though some indices checks may clear faster or take longer, this is the best estimate we have at this time. We understand this will impact start dates, projects, and events, and we are actively exploring ways to minimize these impacts and build in additional efficiencies to our local processes. |
What if there are completed indices checks for a visitor previously? How long do indices checks last?
| Indices checks are applicable for two years. If the visitor has cleared an indices check within two-years of the current request that is being reviewed, they will not need to wait for another at this time. If you are unsure about their status or if the two-year cutoff is close, we suggest erring on the side of caution and planning for an additional 60 calendar days for access. If an individual is from a Sensitive Country but cleared an indices check over two years ago, such “repeat customers” may experience a shorter wait for their indices check, but to be safe, we still recommend you submit a request 60 days before site access is needed. Indices checks apply for two years for both foreign national employees and affiliates as well. However, the lab regularly reviews upcoming renewals and submits them for new indices checks. This process is already in place and will continue; employees will not have to take any additional action. |
Does this impact public events?
| The process for public events has not changed; please follow the public events approval request process. Continue with the normal processes for visitors and participants. |
Does this impact off-site events?
| No, there are no changes or impacts to how we conduct offsite or remote events at this time. |
How does this change the visitor access process?
| Be aware of upcoming collaborations that include foreign nationals from the SCL and submit visitor access requests as early as possible using this new form in order to give as much time as possible for the completion of indices checks. These checks may take up to 60 calendar days to complete. You may also want to consider postponing certain events or visits until a later date, if possible, to ensure that indices checks have time to be completed. The process for visitors from the U.S. or from countries not on the SCL will not be changing. Continue using the standard site access management form for these individuals. In the future, the new form will be integrated into the standard site access form. |
How is the status of an indices check communicated to the host?
| The only notices the host will receive is when the visitor requires indices checks prior to coming on site, and then when the site access request has been approved. There are no status updates in between. We suggest planning for 60 calendar days for indices checks to clear. |
If we know that a new collaborator will need to have site access at some point, can we request a visit for them right away to start the indices check processes, and then cancel the site access request prior to the visit? That way, the indices check would have already been completed in order to turn around site access requests quickly for them in the future if need arises.
| No, this is not an option. You can only submit site access requests for actual meetings/events that are scheduled to happen. |
I’m an employee from a CoR. I’d like to bring a visitor on site who is from another Sensitive Country. What is the new process?
| We understand this is a significant change that may impact your collaborations. Once you fill out the new visitor request form for foreign nationals, if there is an incompatibility and you are unable to bring a visitor from a country on the SCL, FNAP staff will reach out to you to coordinate on identifying an appropriate new host. In many instances, this may be your line manager or someone else in your area who possesses the technical knowledge to oversee the visitor’s activities. You may also proactively ask your line manager or colleague if they meet the requirements to serve as an alternate host, and have them fill out the new visitor request form. There is no change for hosting visitors not on the SCL. |
What about children under 18, vendors, deliveries, rideshares, emergency response personnel, or construction contractors from Sensitive Countries – are they subject to the new visitor access process?
| No. These categories of visitors are exempt from this new policy requirement. They will not require indices checks to come on site. Contractors who receive an LDAP computer account (i.e. lab email) or badge for site access are not exempt. If they are from a country on the SCL, they will need completed indices checks prior to site access or receiving an LDAP. |
Does this change impact site access for current employees and affiliates from Sensitive Countries?
| No. Current lab employees and affiliates have already completed their indices checks and their access to the lab will not be impacted. While indices checks only last for two years, the lab regularly reviews upcoming renewals and submits them for new indices checks. This process is already in place and will continue; employees will not have to take any additional action to maintain their access. |
I am an employee/affiliate from a country on the SCL. Does the rule that appointees need to get DOE approval/completed indices checks affect contract extension or promotion?
| Individuals receiving extensions or promotions are not considered new employees/affiliates under this policy, and therefore do not need to complete indices checks again during contract extension/promotion. However, indices checks are only good for two years. The indices check will automatically renew if already active in DOE’s system (FACTS). Affiliates/employees will not have to take any additional action to maintain their access. |
How will this impact the length of the recruitment and onboarding cycle?
| In general, we are advising that the recruitment process should take into account the additional 60 calendar days for those appointees whose indices checks need to be completed before they can start, and to anticipate potential delays in start dates.This is true for both on-site and remote employees and affiliates. Check back for more details to hiring as they arrive. |
Will hiring processes or the way we write job descriptions change?
| The way we write job descriptions is not changing. The only difference to the hiring process is the indices check will be initiated once the final candidate is identified and before an offer is presented. |
Will the indices checks occur before or after an offer is made to a potential employee?
| The indices checks are part of the pre-hire process, and will be initiated once the final candidate is identified and before an offer is made. The Hiring Manager, HR Solution Center (HRSC), and HR Division Partner listed in our applicant tracking system, Taleo, will be copied in the email notification that goes to our Counter Intelligence (CI) office alerting them that an indices check was initiated. While we are waiting for a response from CI, the offer can be extended and accepted. HRSC will work with the hiring manager to adjust the start date accordingly. HRSC will collaborate with FNAP to keep the hiring manager updated. An HR record will not be created until we receive approval from CI. |
For time-sensitive recruitments, can we identify in a posting that the applicant must be eligible to start by a specific date and provide a link to the FNAP policy so the applicant can determine whether they will be able to meet that requirement to be considered for the position?
| Legally employers are not allowed to ask an applicant their citizenship status. Neither the hiring manager nor the recruiter can ask an applicant to determine or confirm their eligibility based on the indices check process. Applicants are not able to know whether an indices check will apply to them or how long it might take, and the process cannot be used for self-screening. So while a recruitment posting can include information about the expected work start date, we cannot ask applicants to assess or attest to whether they could start within a certain timeframe based on an indices review. |
Do job applicants from countries on the SCL require indices checks prior to coming on site for an interview? And if they cleared the checks for an on-site interview, does that mean they can start right away?
| Yes, any foreign nationals from countries on the SCL coming on site for an interview will require indices checks prior to site access. While requiring onsite interviews can result in the indices check being initiated earlier since applicants must clear that step before coming onsite, we want to remind that it doesn’t guarantee employment at the Lab and the most effective overall strategy for time-sensitive recruitments is to keep the recruitment moving promptly at each stage as quickly as feasible. |
Are we expecting additional changes to FNAP down the line?
| Yes, we are expecting more in FY26. We will remain vigilant assessing and communicating new requirements and being as efficient as possible implementing new procedures. |
Who are FNAP approvers?
| Asmita Patel | Division Deputy, Accelerator Technology & Applied Physics Viviana Oropeza | Security Operations Manager, Personnel Security (OPS) Nicholas Everson | Division Deputy, Joint Genome Institute Jerri Carmo | Area Deputy, Energy Technologies Area Helen Cademartori | Area Deputy, Operations, Computing Sciences Melissa Summers | Area Deputy, Energy Sciences Tracy Mattox | Advanced Light Source, User Office Lead Andrea Taylor | Advanced Light Source, Principal Supervisor, Administrative Services Orlando Casiano | Area Deputy, Earth & Environmental Sciences Area Anthony Spadafora | Division Deputy, Physics Tom Gallant | Division Deputy, Nuclear Science William Fortney | Area Deputy, Physical Sciences Michael Barry | Division Deputy, Engineering |
A Lunch & Learn on the changes to FNAP was held on November 20, 2025. You can view the recording here, which provides an overview of the changes and answers audience questions.
For any critical questions not answered by these FAQs, please reach out to FNAP@lbl.gov.
Additional FAQs for FNAP Approvers and Key Research Operations Personnel
