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Research Compliance and Tech Transfer

Talent Recruitment Programs

Federal research security requirements under the CHIPS and Science Act of 2022 restrict participation in certain foreign talent recruitment programs. 

Federal research sponsors now require disclosure and certification related to foreign talent recruitment programs under the .  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. 

Also, during proposal evaluation, federal funding agencies may determine that participation in certain FTRPs is of sufficiently high risk as to require mitigation prior to award. 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 you must do as a PI, Co-PI, or senior/key personnel 

You have four ongoing obligations: 

  1. Check whether any arrangement you have or may enter into is an FTRP or MFTRP before you submit a federal proposal and during the award. Use the self-check below. Full definitions can be found in the links above. 
  2. Disclose all FTRP participation on your Biosketch, Current and Pending (Other) Support form (typically through SciENcv), Cayuse, and any other agency-specific forms. 
  3. Certify at the time of proposal submission that you are not a party to an MFTRP.  
  4. Recertify annually for the life of each federal award. Across most agencies, MFTRP certification is an individual annual requirement — you typically certify once per year per agency, not award-by-award. 

A 30-second self-check 

Ask yourself these four questions about any foreign arrangement you may have. 

  1. Am I in a foreign program, position or activity compensated with cash or in-kind compensation such as complimentary foreign travel, honorific titles, career advancement opportunities, where the compensation is in exchange for participation or obligation to:  
  2. One or more of the following: 
    1. Unauthorized transfer of intellectual property, materials, data products, or other nonpublic information developed through U.S. federal funding to a foreign government or entity affiliated with a foreign country; 
    2. Being required to recruit trainees or researchers to participate in the program or activity; 
    3. Establishing a lab or company or accepting a faculty position or other employment if these activities are in violation of standard terms and conditions of a federal award 
    4. Being unable to terminate the contract except in extraordinary circumstances; 
    5. Requiring commitments that limit the capacity to carry out a U.S. federal award or would result in substantial overlap or duplication; 
    6. Being required to apply for or successfully receive funding from the sponsoring foreign government’s funding agencies, with the foreign organization as the recipient; 
    7. Being required to omit acknowledgement of the recipient institution (i.e., The 勛圖厙), or the U.S. federal research agency sponsor, contrary to institutional policies or standard award terms and conditions; 
    8. Being required to withhold information about participation in the program and not to disclose it to the U.S. funding agency or to the 勛圖厙; 
    9. Having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the award 
  3. Is the sponsor based in China, Iran, North Korea, or Russia, or on a federal prohibited list (for example, the or the ? 
  4. Activities that are Not Considered Prohibited MFTRP Activities: 

    The following are not considered malign foreign talent recruitment programs unless such activities are sponsored by an academic institution or a foreign talent recruitment program based in China, Iran, North Korea, or Russia, or on a federal prohibited list (for example, the DoD prohibited-entities list or the NDAA Section 1286(c)(8) and (9) list): 
    1. making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law; 
    2. participation 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. other international activities determined appropriate by the Federal research agency head or designee.  

If you are considering an invitation that may meet any of the above criteria of a MFTRP or FTRP please reach out to the Research Security Officer.

Once you have determined your MFTRP/FTRP participation status, you can review instructions in the Agency-Specific Guidance table below. Individual federal agencies conduct research security risk assessments when evaluating funding proposals and may determine that certain activities pose sufficiently high risks as to warrant mitigation prior to award. If you have any questions specific to the agency requirements, please contact the agency or contracting officer directly.   

  • 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 , 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.  
      • The NIH has a list noting the   they require the disclosure of all sources of research support, foreign components, and financial conflicts of interest for senior/key personnel on research applications and awards.  
    • 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 has updated their decision matrix for when mitigation measures will be implemented for FTRP involvement:

  • 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 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  
    • Post-Award Certification: 
      • PIs and co-PI on an active NSF award made on or after May 20, 2024, must certify annually via 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  .   

  • 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 actively 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   documents the factors that DoD takes into account when proposing risk mitigation measures for research projects. Risk mitigation measures are required if the PI, Co-PI, senior/key personnel have any indicators of participation in an MFTRP, or the co-author(s) on publications are participants in an MFTRP.  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 . The requirement for DOE can be found on their website, . 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. 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 . 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, “” and , , .

  • 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.

Foreign Talent Program Summary 

– Effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation. 

It is important to screen foreign collaborators prior to engaging in academic/research activities. UM’s online screening tool, Visual Compliance, allows you to quickly determine whether an entity or individual appears on the prohibited lists below or other U.S. Restricted Party Lists.  

Contact the Research Security Office or the Export Control Office to request screening of potential foreign collaborators.  

FTRP/MFTRP Resources

  • The following definitions are from the  

    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: Why am I hearing about this?  

    A: Federal law requires universities that receive federal research funding to prohibit their researchers from taking part in “malign” foreign talent recruitment programs. If you work on or apply for federal grants, this affects you. The rule comes from Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232).  

    Q: Does this mean I can’t work with international colleagues?  

    A: No. Open, honest international science is encouraged. You can attend international conferences, collaborate openly with colleagues abroad, advise foreign students and write their recommendations, and hold legitimate international appointments. The line is transparency and intent: open and disclosed is fine; secret, deceptive, or in conflict with your U.S. obligations is not.  

    Q: What do I actually have to do?  

    A: Two things. Disclose any participation in any foreign talent recruitment program (malign or not) through your annual conflict-of-interest disclosure and your federal proposal documents. And certify, when a funder requires it, that you are not part of a malign program — for example, NSF asks for this at proposal time and once a year after that.  

    Q: What if I’m not sure whether something crosses the line?  

    A: Ask before you sign anything. A foreign appointment or invitation is not automatically prohibited, but some carry hidden terms that are. The Office of Research can review the specifics with you confidentially — it is far easier to sort out beforehand than after.  

    Q: What is NSF's MFTRP annual certification? 

    A: The MFTRP annual certification is described in the NSF . 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: For an NSF award, 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  and  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 , 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 for an NSF award? 

    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 for NSF? 

    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 for an NSF award? 

    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 for NSF awards? 

    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: Does the NSF have 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  for step-by-step instructions and associated screenshots to complete the MFTRP annual certification. 

    Q: Who should I contact with specific NSF questions? 

    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

  • There are numerous resources on this page but you can scroll down to “Foreign interference and risk mitigation

Have questions? Contact the Research Security Office.