New NSF Disclosure Requirement

Fri, 06 Jun 2025 10:53:53 -0400

As you may have already received an email or have otherwise heard, the U.S. National Science Foundation (NSF) issued a Dear Colleague Letter that stated Principal Investigators and co-PIs named on an NSF award made after 5/20/24 must certify on an annual basis in research.gov that they are not part of a Malign Foreign Talent Recruitment Program (MFTRP). Individuals who are party to an MFTRP are not eligible to serve as senior/key personnel on an NSF proposal. Furthermore, all federal grant funding agencies have similar provisions that prohibit key personnel from participation in an MFTRP.

This new directive from NSF should have very little impact on the UMBC research community as UMBC implemented a question regarding MFTRPs into the Kuali COI disclosure process over a year ago. This new NSF directive doesn't replace UMBC's policy on MFTRPs and yes, unfortunately it does create duplicative reporting requirements. As the UMBC research community receives grants from multiple federal grant funding agencies, and each agency has slight variations on MFTRP prohibitions, we cannot rely exclusively on one federal agency to handle this responsibility on our behalf. Therefore, the MFTRP attestation statement will remain a part of your annual COI disclosure requirements.

MFTRPs, also sometimes referred to Foreign Talent Recruitment Programs (FTRPs), are not uniformly defined by various federal agencies and are considered unmanageable conflicts of interest. MFTRPs are in essence clandestine research programs sponsored by foreign governments, oftentimes who are adversarial to the U.S. government, that fall outside of the scope of normal international collaborations and accepted practices. These programs typically direct participants to not disclose their participation or to even take measures to actively conceal their involvement in the MFTRP from their institution as well as federal grant funding agencies, do not allow for open research publications and may ask participants to engage in activities that would be considered unethical by their institution or even illegal, such as violating U.S. export laws. Should you ever have questions about an international collaboration that you are concerned about, please contact ORPC at researchintegrity@umbc.edu or you can visit Domestic and International Affiliations and Collaborations – Division of Research & Creative Achievement – UMBC for more information.

UPDATE: Below is the question as it appears in Research.gov that requires an answer:

* Required
In accordance with the NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter II.D.1.e(ii) C, all senior/key personnel who are party to a malign foreign talent recruitment program are not eligible to serve on an NSF award made on or after May 20th, 2024. On an annual basis, Pls and co-Pls are required to certify that they are not party to a malign foreign talent recruitment program (MFTRP). For your reference, the definition of an MFTRP can be found here C.

* In your role as a PI or co-Pl, are you party to a malign foreign talent recruitment program?

No

Yes