Per Section 10631 of the CHIPS and Science Act, this document issued in February 2024 from the White House OSTP provides definitions of both foreign talent recruitment programs (FTRPs) and malign foreign talent recruitment programs (MFTRPs) [pages 4-6] and what is not considered an FTRP. 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 or their designee, or an entity based in, funded by, or affiliated with a foreign country.
Agency Disclosure Policies
Agency-specific disclosure requirements, risk-based disclosure reviews, and reporting obligations at the pre-award stage.
Signed January 3, 2020. Section 223 mandates disclosure of funding sources in applications for federal R&D awards and holds universities accountable for ensuring faculty awareness. Section 1299C is an amendment to FY 2019 NDAA Section 1286 requiring designation of an official responsible for liaising with academic institutions and briefing them on espionage risks. Section 1062 restricts DoD and NSF funds to institutions hosting a Confucius Institute. Section 9907 prohibits any funds for microelectronics initiatives to a foreign entity of concern.
Directs NSF to collect annual summaries of foreign financial support from universities. The provision establishes a reporting threshold of $50,000 or more in [cumulative] financial support, including gifts and contracts, received directly or indirectly from a foreign country of concern (China, Russia, North Korea, and Iran at the time the law was enacted), or any other country determined to be a concern by the Secretary of State. This is in addition to the reporting of gifts and contracts from all foreign countries with a cumulative value of $250,000 or more via the Higher Education Act and Department of Education.
September 2022. Requires agencies to implement a due diligence program to assess security risks for SBIR and STTR proposals. Disclosure requirements include information on foreign ties, business relationships, investment, and ownership. [Source: AAU, January 2024].
Issued June 29, 2023 by DoD. The document includes: 1. A Policy on Risk-based Security Reviews of Fundamental Research, 2. A Decision Matrix to Inform Fundamental Research Proposal Mitigation (Amended May 5, 2025), 3. A list of foreign institutions identified as engaging in problematic activity (Part 3, Table 1, Amended June 24, 2025), and 4. A list of foreign talent recruitment programs identified as posing a threat to U.S. national security interests (Part 3, Table 2). The Decision Matrix contains four factors for assessing senior/key personnel disclosures: a. Participation in foreign talent recruitment programs, b. Current or prior funding from foreign countries of concern (FCOCs), c. Filing a patent in an FCOC or on behalf of an FCOC-connected entity, or in a non-FCOC country, without disclosure, and d. Associations or affiliations with organizations on U.S. Entity (trade restriction) and other indicated (U.S. restricted) lists.
Grant Information Circular issued by NASA on February 5, 2026 to implement the research security training (RST) and certification requirements mandated by Section 10634 of the CHIPS and Science Act of 2022 for all research grant and cooperative agreement proposals submitted to the agency. Covered individuals (PIs, Co-PIs, and Co-Is proposing 10 percent or more effort) must certify on their Biographical Sketch and Current and Pending (Other) Support forms that they completed RST within the 12 months prior to proposal submission, with applicant entities certifying via NSPIRES. Requirements take effect August 5, 2026, and NASA recognizes the NSF SECURE Center's Consolidated Training Module (CTM) as a compliant option.
Financial Assistance Letter FAL 2026-02, issued by the U.S. Department of Energy on December 3, 2025, mandating that any DOE notices of funding opportunities (NOFOs), including those from the National Nuclear Security Administration, issued on or after December 3, 2025, require use of the Common Forms via the SciENcv system for Biographical Sketches and Current and Pending (Other) Support (CPS). DOE's adoption of the Biosketch Common Form replaces its prior use of the Resume form, with program offices retaining latitude to specify certain data requirements (such as digital persistent identifier requirements or additional CPS disclosures) within a given NOFO.
Issued July 10, 2019. Reminds institutions receiving NIH funding of the requirement for researchers to disclose all sources of support for their research endeavors, regardless of the source, value, or whether monetary or in-kind, and to disclose all scientific appointments and positions, whether foreign or domestic, paid or unpaid, etc. The notice also reminds the extramural community of the requirement to comply with HHS regulations regarding Financial Conflicts of Interest, as well as the requirement to report all Foreign Components involved in NIH-supported activities.
An NIH form used by recipients with active SBIR and STTR awards to disclose all funded and unfunded relationships with foreign countries. Per NOT-OD-25-102, recipients whose awards did not undergo foreign risk assessment at the time of their original application may be required to use this form, and NIH may terminate awards where a reported covered foreign relationship meets risk criteria prohibiting funding.
Issued December 2, 2025, NOT-OD-26-018 announces NIH's adoption of the Common Forms for Biographical Sketches and Current and Pending (Other) Support. Use of the Common Forms and the NIH Biosketch Supplement is required for applications with due dates on or after January 25, 2026, and for RPPRs and Just-In-Time responses submitted on or after that date, all completed via SciENcv. By February 6, 2026, failure to use the Common Forms generates a submission-blocking error, and the transition incorporates malign foreign talent recruitment program (MFTRP) certifications from institutions and senior/key personnel.
An NIH OPERA document providing illustrative scenarios to help investigators and institutions determine when monetary donations must be disclosed as Other Support versus when they qualify as unrestricted gifts. It explains that donations must be reported as Other Support when intended to directly support an investigator's research activities and carrying explicit or implicit expectations, such as use for specific projects, placement into a research account, or requirements to provide updates to donors. The scenarios correspond with those in the Office of the Inspector General's March 2025 review of institutional understanding of monetary donation reporting.
A March 2025 HHS Office of Inspector General review finding that many institutions receiving NIH funding did not fully understand when monetary donations must be reported as 'Other Support' versus when they qualify as unrestricted gifts. The scenarios in this review correspond with the illustrative scenarios later posted by the NIH Office of Policy for Extramural Research Administration (OPERA) to help investigators and institutions make this determination.
An NIH Guide Notice issued February 4, 2026 confirming that NIH will not withdraw initial applications, JITs, RPPRs, or Prior Approvals submitted on or after January 25 that fail to use the Common Forms via SciENcv for Biographical Sketches, Current and Pending (Other) Support, and NIH Biographical Sketch Supplements. Instead, NIH will provide a warning message when the Common Forms are not used, while still encouraging applicants and recipients to begin using the Common Forms as soon as possible.
February 2023. Outlines advanced monitoring and verification activities of NSF proposals and awards. The guidelines largely serve to provide transparency and identify guardrails NSF has put in place around the use of data analytics to monitor and validate information disclosed (e.g., in biosketches and current and pending support). For example, the activities are not investigative and cannot be incorporated into the merit review process. Sources of information include SCOPUS, Web of Science, and the U.S. Patent and Trademark Office Patent Database.
June 2024. NSF initiated a proposal risk review process similar to that of DoD but with some notable differences. NSF's process will focus on critical technologies, beginning with a pilot of quantum technologies proposals in FY25, expanding to other key technologies in phase 2, and scaling up for all key technologies identified in the CHIPS and Science Act in phase 3. NSF will evaluate Three Criteria: 1. Appointments and positions with U.S. proscribed parties (e.g., U.S. BIS Entity List) and currently party to a MFTRP; 2. Non-disclosures of appointments, activities, and financial support; and 3. Potential foreseeable national security applications of the research. NSF will consider only current foreign appointments and affiliations and is not considering co-authorship in risk assessment.
On December 5, 2025, NSF notified the research community that it is offering a grace period for enforcement of Important Notice No. 149 for proposals submitted between December 2 and December 31, 2025, to accommodate programs with deadlines near the December 2, 2025 effective date. NSF will continue to accept proposals using the previous Biographical Sketch and Current and Pending (Other) Support forms until December 31, 2025; after that date, all proposals must incorporate the new senior/key personnel certifications (research security training within the past 12 months and not being a party to a malign foreign talent recruitment program) required under Important Notice No. 149.
Issued July 8, 2025. This memorandum: a. Requires all USDA Mission Areas, Agencies, and Offices to: i. Within 30 days, conduct a comprehensive review of all current USDA awards/subawards with foreign persons/entities and provide justification as to why a US recipient was not selected, ii. Effective immediately, request approval (including justification) prior to issuing an award/subaward to a foreign person/entity. b. Requires applicants (i.e., covered individuals) to: i. Complete the Common Forms for Biographical Sketches and Current and Pending (Other) Support and provide updated information annually, ii. Certify they are not a participant in a malign foreign talent recruitment program (MFTRP) and recertify annually, iii. Certify that they are not contracting with or providing benefit to any foreign person/entity in a country of concern, iv. Certify that they are not party to utilizing forced labor, v. Complete an annual disclosure of contracts associated with participation in programs sponsored by foreign governments/entities, vi. Seek approval from USDA to subaward any portion of a funded arrangement, including university students, post-doctoral fellows, and visiting researchers. c. Requires Employing Entities to: i. Certify to applicants' completion of research security training, ii. Prohibit applicants who either are currently or have in the past 10 years participated in MFTRPs from working on USDA projects, iii. Provide supporting documentation for foreign activities reported as current and pending support, iv. Review any documents required under the memorandum for compliance with USDA award terms and conditions.
On December 31, 2025, the USDA released a Secretary's Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs), effective immediately, for all future USDA awards. The new General T&Cs include several research security-related requirements, including institutional certification regarding foreign ownership, control, or influence by a country of concern, institutional malign foreign talent recruitment program certification, institutional research security training certification, and institutional certification of Common Form information.
On December 31, 2025, USDA released a Secretary's Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs), applied effective immediately to all future USDA awards. The new General T&Cs include several research security-related requirements: institutional certification regarding foreign ownership, control, or influence by a country of concern; institutional malign foreign talent recruitment program (MFTRP) certification; institutional research security training certification; and institutional certification of Common Form information.