The common form for federal-wide use for current and pending (other) support disclosure, created as directed by NSPM-33 with NSF serving as steward. The form includes certification by each senior/key person at the time of submission that they are not a party to a malign foreign talent recruitment program as defined in the CHIPS and Science Act of 2022. As of November 2025, the form has been implemented by NSF and the National Aeronautics and Space Administration (NASA).
The common form for federal-wide biographical sketch disclosure, created as directed by NSPM-33 with NSF serving as steward. Includes certification by each senior/key person at the time of submission that they are not a party to a malign foreign talent recruitment program as defined in the CHIPS and Science Act of 2022. As of November 2025, the form has been implemented by NSF and NASA.
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.
Signed into law July 26, 2018. Section 1286 directs the Secretary of Defense to establish an initiative to work with IHEs who perform defense research and engineering activities and name an academic liaison. It also directed DoD to publish a list of institutions and foreign talent recruitment programs that have perpetuated malicious activities or that operate under the direction of the military forces or the intelligence agency of the applicable country and thus pose a threat to national security. The resulting list is updated annually.
Published by DoD on June 24, 2025, this document introduces the FY23 lists of foreign institutions identified as engaging in problematic activity and foreign talent recruitment programs identified as posing a threat to U.S. national security, as required by Section 1286 of the FY2019 NDAA.
OSTP to issue guidance to Federal research agencies to prohibit participation in 'foreign talent recruitment programs' by agency personnel and provide additional clarification to the research community regarding which activities are considered 'foreign talent recruitment programs.' OSTP is also directed to issue guidance clarifying that researchers working on Federally supported research projects must disclose participation in FTRPs in Federal research award proposals. OSTP is further directed to issue guidance for Federal research agencies to prohibit researchers working on agency-funded projects from participating in 'malign foreign talent recruitment programs,' and certify both at the time of proposal and annually that they are not part of a malign foreign talent recruitment program.
National Academies: Sciences, Engineering and Medicine|
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A 2024 report by the National Academies: Sciences, Engineering and Medicine examining international talent programs in the context of the changing global environment.
Published July 10, 2025. Includes NSF implementation of three new requirements (and three existing ones) in alignment with the CHIPS and Science Act and NSPM-33. The requirements, effective October 10, 2025, include: a. Recipient institutions must maintain supporting documentation for foreign activities reported as current and pending (other) support, b. Senior/key personnel must certify they have completed research security training (RST) within 12 months prior to proposal submission; Recipient institutions' Authorized Organizational Representative (AOR) must certify that all senior/key personnel have completed required RST and that the institution has a plan to provide appropriate training, c. AORs at institutions of higher education (IHEs) must certify that, absent a waiver granted by the NSF Director, the IHE does not maintain a contract or agreement between the institution and a Confucius Institute.
The CHIPS and Science Act of 2022 directs federal research funding agencies to establish a policy that requires each covered individual (CI) listed in an R&D proposal to certify that they are not a party to a MFTRP in the proposal submission and annually thereafter for the duration of the award. NSF was the first federal agency to implement this certification via the common federal biosketch and current and pending support forms in May 2024. NSF began rolling out the annual certification on June 7, 2025, for all PIs and co-PIs named on an NSF award made on or after May 20, 2024. NSF is making sample contracts available that meet the parameters of a MFTRP. Contract examples and frequently asked questions can be found on the NSF website under MFTRPs.
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.
