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NSF Malign Foreign Talent Recruitment Program

Annual Certification for PIs/co-PIs

Starting June 7, 2025, all Principal Investigators (PIs) and co-Principal Investigators (co-PIs) on NSF awards made on or after May 20, 2024, must annually certify in Research.gov that they are not involved in a Malign Foreign Talent Recruitment Program (MFTRP), as required by NSF policy (PAPPG Chapter II.D.1.e(ii)).
Anyone currently involved in an MFTRP cannot serve as senior/key personnel on NSF proposals or awards made on or after May 20, 2024. NSF will notify affected individuals about this new requirement. 
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Please note that the University created policy R7-001A: Prohibition of Participation in Malign Foreign Talent Recruitment Programs to comply with the CHIPS and Science Act of 2022, which prohibits federal agencies from funding researchers participating in an MFTRP.

Background

The National Science Foundation (NSF) Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 24-1) went into effect May 20, 2024.

One significant change was the Chapter II.D.1.e(ii), Malign Foreign Talent Recruitment Programs (FTRPs). This new section addresses Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232) regarding malign foreign talent recruitment programs.

 


New Certification Requirements

All individuals designated as senior/key personnel on NSF proposals must certify that they are not a party to a malign foreign talent recruitment program.  

Individuals who are party to a Malign Foreign Talent Recruitment Program are not eligible to serve as a senior/key person on an NSF proposal. 

 What you need to know about completing the required MFTRP certification in Research.gov:

    • There is no organizational certification requirement, the certification requirement is for PIs and co-PIs. This certification is provided separately for each individual designated as senior/key personnel on the proposal.
    • Impacted PIs and co-PIs will be prompted to complete the MFTRP certification after signing into Research.gov using the Sign In link at the top of www.Research.gov.
    • PIs and co-PIs with more than one active award made on or after May 20, 2024, are only required to certify once, annually.
    • Once completed, PIs and co-PIs can view their MFTRP certification response under the Academic/Professional Information section of their profile.
    • NSF is working to expand the MFTRP annual certification requirement for all senior/key personnel roles at a future date. Additionally, NSF is working to provide organizations with access to the annual certifications.
    • Frequently Asked Questions and MFTRP contract examples will be available on the MFTRP section of the Office of the Chief of Research Security Strategy and Policy website shortly.

Updated Biographical Sketch and Current and Pending (Other) Support

  Any proposal missing this updated signed certification for a senior/key person will be rejected or withdrawn for non-compliance.

Prior to making funding recommendations, the NSF program officer will request updated versions of the Current and Pending (Other) Support be submitted via Research.gov.

Re-certification is required annually thereafter for the duration of the award. Updated Current and Pending (Other) Support must be disclosed to NSF when annual and final progress reports are submitted.

24-1 pappg

 

  • Before updating to the 24-1 versions, be sure to copy over the synergistic activities. These will automatically be removed when converting to the 24-1 version.
  • For detailed information about the conversion from 23-1 to 24-1 formats and the required certifications, please watch this NSF implementation webinar (April 25, 2024).

 


Foreign Influence Consultation

Individuals are required to completely and accurately disclosure all foreign relationships in the University Business Relationship Reporting (BRR) system. These disclosures should match what is being reported and certified on the SciENcv documents.

Anyone who has been approached with an opportunity to join a FTRP or is unsure whether they are involved in a FTRP should request a foreign influence consult with the Office of Foreign Influence.

Anyone unfamiliar with the topic of foreign influence should register for RED 352 | Foreign Influence: Heightened Awareness and Increased Activity (online).

NSF Definition of Malign Foreign Talent Recruitment Programs 

Any program, position, or activity that is sponsored by one of the following:

    • A foreign country of concern (defined as the People's Republic of China including Hong Kong and Macau, the Democratic People's Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country determined to be a country of concern by the Secretary of State); or
    • An entity based in a foreign country of concern; or
    • An institution or program on certain prohibited lists (contact OSP for restricted party screening).

AND

Involves one or more of the following:

    • Unauthorized transfer of intellectual property, materials, data or other nonpublic information;
    • Recruitment of trainees or researchers to enroll in such program, position or activity;
    • Establishing a laboratory or entity in a foreign country in violation of terms and conditions of a federal research award;
    • Accepting a faculty position, or undertaking any other employment or appointment in violation of the standard terms and conditions of a federal research award;
    • Being unable to terminate the activity except in extraordinary circumstances;
    • Being limited in capacity to carry out a federal research award;
    • Requirement to engage in work that overlaps or duplicates a federal research award;
    • Requirement to obtain research funding from the foreign government’s entities;
    • Requirement to omit acknowledgement of the U.S. home institution and/or the federal funding agency;
    • Requirement to not disclose participation in the program, position, or activity; OR 
    • Having a conflict of interest or commitment contrary to a federal research award.

Questions re: NSF certifications should be sent to your Sponsored Projects Officer

Last Updated: 6/4/25