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Research Compliance and Tech Transfer

Talent Recruitment Programs

Federal research security requirements under the CHIPS and Science Act restrict participation in certain foreign talent recruitment programs.

Federal research sponsors now require disclosure and certification related to foreign talent recruitment programs under the CHIPS and Science Act of 2022.  As a PI, co-PI, or senior/key personnel you are required to disclose participation in a Foreign Talent Recruitment Program (FTRP) and must certify that you are not participating in a Malign Foreign Talent Recruitment Program (MFTRP) to submit proposals and maintain federal research awards. 

All researchers who engage in or propose engaging in research projects at UM – federally-sponsored, non-federally sponsored, and unsponsored – are prohibited from participating in MFTRPs.  

What This Means for You as a PI, Co-PIs, or senior/key personnel - What You Need to Do 

Step 1

Determine whether an arrangement qualifies as an FTRP or MFTRP. Federal funding agencies prohibit PIs, Co-PIs and senior/key personnel from participating in MFTRPs, as required by the CHIPS and Science Act of 2022. 

  • To help you determine whether an arrangement is a FTRP or a MFTRP use the table below. If you need more information see the definitions for FTRP and MFTRP and the FAQ.
  • Not all Foreign Talent Recruitment Programs are malign. However, if you meet at least one of the criteria from Box A, at least one factor from Box B, and at least one factor from Box C below, you are participating in an MFTRP: 
    FTRP or MFTRP qualification table

    A. Program, Position, or Activity: Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue. 

    B. Problematic Obligation or Participation: 

    In exchange for the individual- 

    1. engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;  
    2. being required to recruit trainees or researchers to enroll in such program, position, or activity; 
    3. establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;  
    4. being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances; 
    5. through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award; 
    6. being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient;  
    7. being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award; 
    8. being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or  
    9. having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award; 

    C. Problematic Sponsorship: 

    And the program is sponsored by- 

    1. A foreign country of concern (FCOC)currently defined as: 
      • China (includes Hong Kong and Macau) 
      • Cuba 
      • Iran 
      • North Korea 
      • Russia 
      • Venezuela 
    2. an entity based in a FCOC, whether or not the program is directly sponsored by the government of the FCOC; or 
    3. an academic institution or a foreign talent recruitment program identified on the list developed under section 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 

    *See below for DoD 
  • *Important: If you have an award with the DoD they have expanded their list of Prohibited Entities. Please view the 2026 Department of Defense Component Decision Matrix and their list of prohibited entities. If your contract is with another federal agency, it is recommended to check with your Contracting Officer to inquire if they have adopted the DoD’s list. 

Step 2

Follow sponsor specific instructions for certification (NIH, NSF, DoD, DOE, NASA, EPA, DARPA, USDA, etc.). You can view the tabs below or, refer to current agency specific guidance in the Research Security Matrix (go to row 12) or this Quick Reference Table. 

Step 3

Disclose FTRP participation when required by the agency. 

  • Participation in a Foreign Talent Recruitment Program must be disclosed to Federal Sponsors. Some agencies use the Common Form for the Biographical Sketch but it is not harmonized yet through all the federal agencies. Use the reference table below or contact the Sponsor’s Contracting Officer for more information. 

Step 4

Certify you are not participating in an MFTRP when required by the agency: 

  • The Science Experts Network Curriculum Vitae (SciENcv) which is currently mandated by the National Science Foundation (NSF), and recommended for use by other funding agencies uses the Common Form for the Biographical Sketch recommended by the Office of Science and Technology (OSTP) that includes the recommended certification (“I also certify that, at the time of submission, I am not a party to a malign foreign talent recruitment program”. 
Agency-Specific Guidance

Federal agencies such as the National Institutes of Health (NIH), Department of Defense (DoD), Environmental Protection Agency (EPA), National Science Foundation (NSF), Department of Energy (DOE), National Aeronautics and Space Administration (NASA), The Defense Advanced Research Projects Agency (DARPA), United States Department of Agriculture (USDA), and the Army Research Lab (ARL) have different approaches to reviewing international collaborations, but all prohibit investigators from participating in MFTRPs. Please see this Reference Table of Current and Upcoming Federal Research Security Requirements.  * The “Biographical Sketch Common Form” and the “Common Form for the Biographical Sketch” are different phrasings for the same NSPM‑33 and SciENve standardized federal biosketch form, with no difference in content or requirements. The National Institutes of Health (NIH) uses the former and the National Science Foundation (NSF) uses the latter. 

  • Effective January 25th, 2026, individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP) are not eligible to serve as a senior/key person on a National Institute of Health (NIH) grant or cooperative agreement.  

    • Individual certifications are required. At the time of application PIs, Co-PIs and individuals identified as senior/key personnel will be required to certify on their Biographical Sketch Common Form, attached on the R&R Senior/Key Person Profile (Expanded) Form, that they are not party to a malign foreign talent recruitment program. Effective January 25th, 2026.   
    • Institutional certifications are required as well. The Authorized Organizational Representative (AOR) must certify that all individuals identified by the applicant as senior/key personnel have been made aware of and have complied with their responsibility under that section to certify that the individual is not a party to a malign foreign talent recruitment program.  
    • Annual Certification is due at the time of Research Performance Progress Report (RPPR) submissions. For NIH awards with RPPRs submitted on or after January 25, 2026, individuals serving as senior/key personnel must certify annually to their participation or non-participation in an MFTRP by uploading a certification statement in Section G.1, Special Notice of Award and Funding Opportunity Announcement Reporting Requirements as a flattened PDF file. The file for each senior/key person must be named ‘MFTRPcert_[Name].pdf’ without quotations, where ‘[Name]’ is the name of the senior/key person. 
    • Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support and NIH Biographical Sketch Supplement will be required for application due dates and all JIT, RPPR, and Prior Approval submissions on or after January 25, 2026. 
    • NIH’s Implementation of Common Forms for Biographical Sketch and Current and Pending (Other) Support for Due Dates on or after January 25, 2026 

  • Starting on June 7, 2025, in accordance with the NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter II.D.1.e(ii), all PIs, co-PIs, and senior/key personnel named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov. that they are not party to a MFTRP. 

    •  Individuals who are currently a party to a MFTRP are not eligible to serve as senior/key personnel on an NSF proposal or on any NSF award made on or after May 20, 2024.  
    • Pre-Award Certifications: 
      • The AOR must certify that a PIs, co-PIs and senior/key personnel have been made aware of and have complied with their responsibility under that section to certify that the individual is not a party to a malign foreign talent recruitment program. 
      • Each PI, co-PI, and senior/key personnel must individually certify that they are not a party to a malign foreign talent recruitment program. The pre-award disclosures in the Biographical Sketch and Current and Pending (Other) Support 
    • Post-Award Certification: 
      • PIs and co-PI on an active NSF award made on or after May 20, 2024, must certify annually via Research.gov to their participation or non-participation in a MFTRP. Note: The NSF intends to expand the post-award annual MFTRP certification requirement to all senior/key personnel at a future date. 

    Helpful information can be found at the  NSF Research Security webpage.   

  • Beginning August 9, 2024, the Department of Defense (DoD) is prohibited from providing funding to or making an award in which a covered individual (e.g. PI, Co-PI, or senior/key personnel) is participating in a MFTRP or to a proposing institution that does not have a policy addressing malign foreign talent programs pursuant to Section 10632 of the CHIPS and Science Act of 2022. Currently, you will need to consult the individual component forms to determine if they contain certification of no MFTRP participation.  In addition, DoD conducts risk-based security reviews of proposals. The  risk matrix documents the factors that DoD takes into account when proposing risk mitigation measures for research projects.  The DoD certification process for MFTRP is in progress and has not yet been released. 

  • The Department of Energy (DoE) has tightly restricted talent program participation since 2019 under DoE Order 486.1A. The requirement for DOE can be found on their website, Prohibition on MFTRP. Certification of no participation in MFTRP is required for PIs, co-PIs and senior/key personnel at the time of application in Current and Pending Support Disclosure form. Order 486,1A prohibits DOE contractor personnel from participating in foreign country of risk talent recruitment programs (FCRTRP). 

  • Environmental Protection Agency has forms for disclosures available at their website. They do not have a process for MFTRP certification to date. 

  • PIs, Co-PIS and senior/key personnel are prohibited from participating in MFTRPs & participants may not receive DARPA funding. DARPA requires certification of no MFTP participation in Common Disclosure Forms.  

  • MFTRP certification is required in the current and pending support disclosure form. National Aeronautics and Space Administration uses Common Disclosure Forms. Information regarding the disclosure process can be found in, “Notice of Information Collection, Request for Comments: Biosketch and Current and Pending Support Disclosure Policy” and NASA Mar. 2025 Grants & Coop. Agreements Terms & Conditions (GCATC), Mar. 2025 Grant & Agreement Manual (GCAM), & Oct. 2024 Pre and Post-Award Disclosure Table.

  • The PI, Co-PI and senior/key personnel must certify that they are not participating, and have not participated within the past 10 years, in a  malign foreign talent recruitment program. Each such individual must certify on the Common Form for Current and Pending (Other) Support and a Common Form for Biographical Sketch via SciENcv that they are not party to a malign FTRP and agree to an annual recertification for the duration of the award.

Step 5

Once you have disclosed FTRP activities and certified that you are not party to an MFTRP be ready to complete this annually for the federal agency. 

Step 6

There will be questions in Cayuse asking if you have completed the disclosure of participation in a FTRP and certified to non-participation in an MFTRP.

FTRP/MFTRP Resources

  • The following definitions are from the Proposal & Award Polices & Procedures Guide (PAPPG) 

    Award - means an NSF grant or cooperative agreement. 

    Grant Agreement - a legal instrument of financial assistance between NSF and a recipient that, consistent with 31 USC §§ 6302, 6304: 

    1. Is used to enter into a relationship the principal purpose of which is to transfer anything of value from NSF to the recipient to carry out a public purpose authorized by a law of the United States (see 31 USC § 6101(3)); and not to acquire property or services for NSF’s direct benefit or use; 
    2. Is distinguished from a cooperative agreement in that it does not provide for substantial involvement between NSF and the recipient in carrying out the activity contemplated by the NSF award. 

    NSF makes the following two types of grants: 

    • Standard Grant: a type of grant in which NSF agrees to provide a specific level of support for a specified period of time with no statement of NSF intent to provide additional future support without submission of another proposal. 
    • Continuing Grant: a type of grant in which NSF agrees to provide a specific level of support for an initial specified period of time, usually a year, with a statement of intent to provide additional support for the project for additional periods, provided funds are available and the results achieved warrant further support. 
    Cooperative Agreement - a legal instrument of financial assistance between NSF and a recipient that, consistent with 31 U.S.C. §§ 6302–6305: 
    1. Is used to enter into a relationship the principal purpose of which is to transfer anything of value from NSF to the recipient to carry out a public purpose authorized by a law of the United States (see 31 U.S.C. § 6101(3)); and not to acquire property or services for NSF’s direct benefit or use; 
    2. Is distinguished from a grant in that it provides for substantial involvement between NSF and the recipient in carrying out the activity contemplated by the NSF award. 

    In the case of NSF, grants and cooperative agreements involve the support or stimulation of scientific and engineering research, science and engineering education or other related activities. NSF is authorized to use grants and cooperative agreements for this purpose. Grants, however, are the primary mechanism of NSF support. 

    Covered individual or Senior/key personnel – an individual who (a) contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a federal research agency; and (b) is designated as a covered individual by the federal research agency concerned. Consistent with NSPM-33, this means principal investigators (PIs) and other senior/key personnel seeking or receiving federal research and development funding (i.e., extramural funding) and researchers at federal agency laboratories and facilities (i.e., intramural researchers, whether or not federally employed), including Government-owned, contractor-operated laboratories and facilities.   

    Foreign Country of Concern - means the People's Republic of China, the Democratic People's Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country deemed to be a country of concern as determined by the Secretary of State. 

    Foreign Talent Recruitment Program - A foreign talent recruitment program is any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.

    Consistent with Section 10632(d) of the Act, a foreign talent recruitment program does not include the following international collaboration activities, so long as the activity is not funded, organized, or managed by an academic institution or a foreign talent recruitment program on the lists developed under paragraphs (8) and (9) of Section 1286(c) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232):

    1. Making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law;
    2. Participating in international conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law;
    3. Advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student, at such student's request; and
    4. Engaging in the following international activities:
      • Activities that are partly sponsored or otherwise supported by the United States such as serving as a government appointee to the board of a joint scientific fund (e.g., the U.S.- Israel Binational Industrial Research and Development Foundation); providing advice to or otherwise participating in international technical organizations, multilateral scientific organizations, and standards setting bodies (e.g., the International Telecommunications Union, Intergovernmental Panel on Climate Change, etc.); participating in a Fulbright Commission program funded in whole or in part by a host country government; or other routine international scientific exchanges and interactions such as providing invited lectures or participating in international peer review panels.
      • Involvement in national or international academies or professional societies that produce publications in the open scientific literature that are not in conflict with the interests of the federal research agency (e.g., membership in the Pontifical Academy of Sciences or The Royal Society).
      • Taking a sabbatical, serving as a visiting scholar, or engaging in continuing education activities such as receiving a doctorate or professional certification at an institution of higher education (e.g., the University of Oxford, McGill University) that are not in conflict with the interests of the federal research agency.
      • Receiving awards for research and development which serve to enhance the prestige of the federal research agency (e.g., the Nobel Prize).
      • Other international activities determined appropriate by the federal research agency head or designee.

    Malign Foreign Talent Recruitment Program  - (A) Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual—

    • engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products; 
    • being required to recruit trainees or researchers to enroll in such program, position, or activity; 
    • establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award; 
    • being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;
    • through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award, or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award; 
    • being required to apply for and successfully receive funding from the sponsoring foreign government’s funding agencies with the sponsoring foreign organization as the recipient; 
    • being required to omit acknowledgment of the recipient organization with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award; 
    • being required to not disclose to the Federal research agency or employing organization, the participation of such individual in such program, position, or activity; or 
    • having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award. And
    (B) A program that is sponsored by— 
    • a foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern; 
    • an academic institution on the list developed under § 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. § 2358 note; Public Law 115–232); or 
    • a foreign talent recruitment program on the list developed under § 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. § 2358 note; Public Law 115–232).

  • Q: What is the MFTRP annual certification? 

    A: The MFTRP annual certification is described in the NSF PAPPG Chapter II.D.1.e(ii). Individuals who are currently party to a MFTRP are not eligible to serve as senior/key personnel on an NSF proposal or on any NSF award made on or after May 20, 2024. Starting on June 7, 2025, Principal Investigators (PIs) and co-Principal Investigators (co-PIs) must certify on an annual basis that they are not party to an MFTRP. NSF will implement the MFTRP annual certification requirement for all other senior/key personnel roles at a future date. Other Federal funding agencies have followed the NSF, prohibiting PIs, Co-PIs and senior/key personnel from participating in MFTRPs, as required by the CHIPS and Science Act of 2022.

    Q: Is a PI or co-PI named on multiple active NSF awards made on or after May 20, 2024, required to complete the MFTRP annual certification for each award? 

    A: PIs and co-PIs named on multiple active NSF awards made on or after May 20, 2024, must complete the MFTRP annual certification once each year to cover all active awards. The certifications are linked to the users registered in Research.gov with a PI or co-PI role and at least one active NSF award made on or after May 20, 2024. If you have awards from different federal agencies be prepared to certify annually for each agency.

    Q: Must all senior/key personnel named on an NSF award made on or after May 20, 2024, certify annually that they are not party to a MFTRP? 

    A: Starting on June 7, 2025, all PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify that they are not party to a MFTRP on an annual basis. NSF intends to expand the MFTRP annual certification requirement for all senior/key personnel roles at a future date.

    Q: How will I be notified each year when I am required to complete my MFTRP annual certification in Research.gov?

    A: When you are required to certify, a pop-up message will display in Research.gov after you sign in to notify you that you must complete your MFTRP annual certification and what steps you need to take in Research.gov to complete the certification.

    Q: Is the MFTRP annual certification different from the MFTRP certifications in the pre-award disclosure documents submitted with an NSF proposal?

    A: Yes, the MFTRP annual certification is different. The pre-award disclosures in the Biographical Sketch and Current and Pending (Other) Support proposal sections described in PAPPG Chapter II.B.1 and Chapter II.D.1.e require that all individuals designated as senior/key personnel complete an MFTRP certification for each NSF proposal. The MFTRP annual certification is a post-award requirement. Pursuant to PAPPG Chapter II.D.1.e(ii), all individuals serving as a PI or co-PI on at least one active NSF award made on or after May 20, 2024, will be required to submit their MFTRP certification annually. 

    Q: Will a PI or co-PI who transfers to another organization have to recertify? 

    A: No. A PI or co-PI who transfers to another organization will not need to recertify. MFTRP annual certifications are linked to Research.gov users with a PI or co-PI role and an active award made on or after May 20, 2024, and not to their organizations. 

    Q: How can a PI or co-PI check whether they have already completed a MFTRP annual certification? 

    A: PIs and co-PIs can view their most recent MFTRP annual certification response under the Academic/Professional Information section of their profile by signing into Research.gov and selecting My Profile at the top of the screen. 

    Q: Can a PI or co-PI change their response to the MFTRP annual certification? 

    A: To change a response to the MFTRP annual certification, please email researchsecurity@nsf.gov for guidance. 

    Q: How long is my Malign Foreign Talent Recruitment Program annual certification valid? 

    A: The certification is valid for one year. A PI or co-PI named on an active award made on or after May 20, 2024, must certify in Research.gov each year. 

    Q: Are there instructions for how to complete the MFTRP annual certification? 

    A: Please see the Add a New Organization-Approved Role - Principal Investigator PI/Co-PI job aid in the Account Management User Guide for step-by-step instructions and associated screenshots to complete the MFTRP annual certification. 

    Q: If I have additional questions, who should I contact? 

    A: Please contact the NSF Office of the Chief of Research Security Strategy and Policy at researchsecurity@nsf.gov for more information. System-related questions should be directed to the NSF IT Service Desk at 1-800-381-1532 (7:00 AM - 9:00 PM ET; Monday - Friday except federal holidays) or rgov@nsf.gov. 

    Q: If I have multiple awards with a federal agency am I required to certify for each award?

    A: Across federal research agencies, the MFTRP certification is generally treated as an individual‑based, annual requirement (not award‑by‑award). A PI or co‑PI named on multiple active awards typically certifies once per year, unless the agency explicitly requires otherwise. If you have awards from different federal agencies be prepared to certify annually for each agency.

Helpful Links

Have questions? Contact the Research Security Office @ researchsecurity@umontana.edu