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Research Security
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Principal Investigator / Senior Key Personnel

Researchers with personal disclosure, training, and certification obligations on federal awards.

46 relevant references

Key Deadlines

May 1, 2025

DoE Financial Assistance Letter (FAL): Research Security Training Requirements for all R&D Financial Assistance Awards

DoE research security training requirement becomes mandatory

DOE
May 1, 2025

DoE Financial Assistance Letter (FAL): Digital Persistent Identifier Requirements for Certain Individuals for Research and Development

PID requirement becomes mandatory for DoE financial assistance applications

DOE
Jun 7, 2025

NSF Important Notice No. 149

NSF begins rolling out annual MFTRP certification for PIs/co-PIs

NSF
Sep 30, 2025

Updated NIH Policy on Foreign Subawards (NOT-OD-25-104)

NIH anticipates implementing new foreign subaward structure

NIH
Oct 1, 2025

NIH Announces a New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements (NOT-OD-25-133)

NIH Other Support disclosure training requirement takes effect

NIH
Oct 10, 2025

NSF Important Notice No. 149

NSF Important Notice 149 requirements take effect

NSF
Oct 24, 2025

NIH Policy on Enhancing Security Measures for Human Biospecimens (NOT-OD-25-160)

NIH biospecimens security policy takes effect

NIH

Disclosure Requirements

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Transparency of Foreign Connections Disclosure and Certification

ActiveDOE

For applicants, recipients, and subrecipients that are required to submit transparency of foreign connections disclosures, DOE provides this format for the convenience of the entity providing the disclosure and certification; however, the entity is not required to use this specific format. If another format is used, the signatory must include the same substantive information, a signature, date, and the certification statement provided in Section 3 of the document.

Preview of NIH Common Forms for Biographical Sketch and Current and Pending (Other) Support Available in SciENcv

ActiveNIHSep 4, 2025

On September 4, 2025, NIH issued notice NOT-OD-25-152, regarding the agency's plans to release preview versions of NIH's Common Forms for Biographical Sketches (Biosketches) and Current and Pending (Other) Support in the Science Experts Network Curriculum Vitae (SciENcv) system. Access to the preview versions is purely for informational purposes and applicants/recipients may not submit documents to NIH that were created using the preview functionality. Applicants/recipients must continue to use the current NIH Biosketch and Other Support forms until NIH officially implements its Common Forms, which the agency anticipates will occur in November 2025. The fall 2025 government shutdown may impact this timeline.

NSF Important Notice No. 149

ActiveNSFJul 10, 2025

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.

America First Memorandum for USDA Arrangements and Research Security

ActiveUSDAJul 8, 2025

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.

Notice of Information: NIH SBIR and STTR Foreign Disclosure Post-Award Requirements for Active SBIR and STTR Awardees (NOT-OD-25-102)

ActiveNIHApr 29, 2025

Effective immediately (April 29, 2025), the SBIR and STTR Foreign Disclosure and Risk Management Requirements described in NOT-OD-23-139 and NOT-OD-24-029 may be applied to all active SBIR and STTR awards regardless of the due date the competing application was submitted. Recipients with active awards that did not undergo foreign risk assessment at the time of their original application may be required to disclose all funded and unfunded relationships with foreign countries, using the Required Disclosures of Foreign Affiliations or Relationships to Foreign Countries Form. If the recipient reports a covered foreign relationship that meets any of the risk criteria prohibiting funding, NIH may deem it necessary to terminate the award for material failure to comply with the federal statutes, regulations, or terms and conditions of the federal award.

DoE Financial Assistance Letter (FAL): Digital Persistent Identifier Requirements for Certain Individuals for Research and Development

ActiveDOEAug 8, 2024

Issued on August 8, 2024. Effective May 1, 2025, applicants are required to have a Digital Persistent Identifier or Persistent Identifier (PID) if: 1. Individuals are listed within financial assistance applications that will fund R&D activities, or technical assistance to support R&D activities; and 2. Individuals are required to submit Biographical Sketch and/or Current and Pending (Other) Support disclosure. A PID is defined as globally unique, persistent, machine resolvable and processable, and has an associated metadata schema (example: ORCID iD). PIDs must be provided in the Biographical Sketch and/or Current and Pending (Other) Support disclosures as part of the application. This requirement is optional until May 1, 2025, and mandatory thereafter.

Current and Pending (Other) Support Common Form

ActiveFederalNov 1, 2023

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).

Biographical Sketch Common Form

ActiveFederalNov 1, 2023

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.

NASA Proposer's Guide

ActiveNASAFeb 1, 2023

The NASA Proposer's Guide (February 2023) includes similar language to the Wolf Amendment in a footnote of section 2.16, Current and Pending Support. Per the footnote, 'China or Chinese-owned Company' means the People's Republic of China (PRC), any company owned by the PRC, or any company incorporated under the laws of the PRC. Chinese universities and other similar institutions are considered to be incorporated under the laws of the PRC and, therefore, the funding restrictions apply to grants and cooperative agreements that include bilateral participation, collaboration, or coordination with Chinese universities.

Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021 (NOT-OD-21-073)

ActiveNIHMar 1, 2021

Issued March 2021. Requires immediate notification of undisclosed Other Support. If a recipient discovers Other Support information on an active NIH grant that should have been, but was not, disclosed during just-in-time or in an annual progress report, updated Other Support must be submitted to the Grants Management Specialist as soon as the undisclosed information is known.

National Security Presidential Memorandum-33 (NSPM-33): Presidential Memorandum on U.S. Government-Supported Research and Development National Security Policy

ActiveFederalJan 1, 2021

A Presidential Memorandum issued in January 2021 to strengthen protections of U.S. Government-supported R&D against foreign government interference and exploitation. It focuses on ensuring full disclosure of potential conflicts of interest and commitment by recipients of federal R&D and requires research institutions receiving over $50 million in federal R&D funding to certify they operate a research security program covering cybersecurity, foreign travel security, insider threat awareness, and export control training. As of November 2025, federal agencies continue to coordinate and work to implement this requirement for awardee institutions.

Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114)

ActiveNIHJul 10, 2019

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.

Research Security Programs

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Research Program on Research Security (JASON, March 2023)

ActiveNSFMar 1, 2023

A March 2023 report issued by JASON and commissioned by NSF. Provides definitions of Research Integrity as adherence to accepted values and principles -- objectivity, honesty, openness, accountability, fairness, and stewardship -- that guide the conduct of research. Research Security is protecting the means, know-how, and products of research until they are ready to be shared. JASON suggests research security does not vary across disciplines, but the consequences of breaches in research security and the measures taken to prevent breaches will differ. Key points include an emphasis on training researchers on risks in international collaborations, the need to encourage collaboration with international organizations that are also concerned with research security, and avoiding creating a reputation of racial profiling or using the research security programs to disadvantage anyone based on ethnicity or nationality.

Risk Assessment & Mitigation

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Trusted Research Using Safeguards and Transparency (TRUST)

ActiveNSFJun 1, 2024

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.

Safeguarding the Research Enterprise (JSR 23-12)

ActiveNSFMar 1, 2024

A March 2024 report commissioned by NSF and issued by the JASON group. Recommends NSF adopt a dynamic approach for identifying potentially sensitive research topics as they arise and weigh the balance between the protective benefits and the unintended negative consequences of controls on sensitive research. It is suggested that the identification of sensitive projects proposed to NSF occurs most naturally before peer or panel review. Specific mitigation strategies for sensitive research projects should be negotiated and agreed upon by the principal investigator (PI), NSF, and the institution and be proportionate to the assessed risk, relative to the associated costs.

Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education

ActiveDoDJun 29, 2023

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 without disclosure, and d. Associations or affiliations with organizations on U.S. Entity (trade restriction) and other indicated (U.S. restricted) lists.

Fundamental Research Security (JSR-19-21)

ActiveNSFDec 1, 2019

A December 2019 report from the JASON Group commissioned by NSF. The report outlines that concerns of foreign influence can be addressed within the framework of research integrity and, in addition, that the benefits of openness in research and of the inclusion of foreign researchers dictate against measures that would restrict fundamental research. The report includes questions for researchers to consider when entering a collaboration [Section 7.3 Assessment Tools: pages 34-36].

China Defense Universities Tracker

ActiveFederalJan 1, 2019

A searchable database that provides ratings on 'risk' for collaboration with an entity. In addition to the tracker, an associated document (released in 2019): Exploring the military and security links of China's universities.

Training & Certification

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DoE Financial Assistance Letter (FAL): Research Security Training Requirements for all R&D Financial Assistance Awards

ActiveDOEOct 7, 2024

Issued on October 7, 2024, this document outlines DOE's implementation of research security training requirements for covered individuals on financial assistance applications and for organizations applying for an award. The requirement was effective immediately but not mandatory until May 1, 2025. The training requirement is satisfied either by completion of the four training modules created by NSF, completion of the SECURE Center CTM (as indicated per DOE post FAL), or by a custom training program that is aligned with the CHIPS and Science Act Section 10634(b). Per DOE the training must be completed within the 12 months immediately preceding the application submission, consistent with the CHIPS Act requirements, and any covered individuals added to the project must certify that they have completed the training within 30 calendar days of joining the project.

University of Michigan Condensed Federal Research Security Training

ActiveFederalJan 1, 2024

A condensed and consolidated one-hour version of the four federal training modules developed by the University of Michigan in collaboration with Ohio State University, Stanford University, and Duke University. Other academic institutions or organizations can download for their use. The training includes two editable html-based files that can be modified to supply institution-specific contact information and links to resources. SCORM files, Storyline file, and written version of the narrative are available.

SECURE Center Condensed Training Module (CTM) 1.1

ActiveFederalJan 1, 2024

An updated one-hour condensed and consolidated federal research security training module offered by the SECURE Center. NSF, NIH, DoD, DOE, and USDA have indicated that the condensed module meets their research security requirements. The SCORM files (for upload in the institution's learning management systems), Storyline file, and transcript can also be found on the website. The training includes two, four or six editable html-based files that can be modified to supply institution-specific contact information and links to resources. A preview version can be viewed on the website and a version that offers a certificate of completion is now available.

Research Security Training

ActiveFederalJan 1, 2023

Research security training developed by institutions and organizations under cooperative agreements funded by NSF in collaboration with the National Institutes of Health (NIH), Department of Energy (DoE), and Department of Defense (DoD), with engagement from the Federal Bureau of Investigation (FBI). The training consists of 4 modules: 1.) What is Research Security?; 2.) Disclosure; 3.) Manage and Mitigate Risk; 4.) International Collaboration.

Export Controls

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DoD Fundamental Research Guidance

ActiveDoDAug 4, 2025

Published August 4, 2025, this guidance provides background on Fundamental Research (FR) as defined by NSDD-189 and DoD's implementation of the Directive via the May 24, 2010 'Carter Memo'. The Guidance notes that 'under the Carter Memo, research funded by 6.1 budget activity or 6.2 research conducted on a university campus is fundamental. For other research categories, the Department must be deliberate when deciding that a particular research topic is appropriate for openly published fundamental research'. It incorporates Considerations for Program Managers and Contracts and Grants Officers, including: a. Refraining from imposing publication review of research that has been formally designated as fundamental; b. For awards with multiple performers, considering whether some portion of the work should be designated as FR even if much of the award is not; and c. Avoiding flowing down restrictions to awardees performing FR that are inappropriate for FR. In addition, no security vetting should be done on personnel engaged in fundamental research and no preapproval conditions for the addition of researchers.

Foreign Talent Recruitment Programs

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NSF Annual Malign Foreign Talent Recruitment Program Certification for PIs/co-PIs

ActiveNSFJun 7, 2025

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.

Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs

ActiveFederalFeb 1, 2024

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.

International Collaboration

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Additional Information on NIH New Application and Award Structure for International Collaborations

ActiveNIHSep 18, 2025

On September 18, 2025, NIH released additional information regarding the agency's new application and award structure for international collaborations, previously announced in NIH NOT-OD-25-155. In addition to summarizing impacts to proposing/recipient institutions, the announcement provides links to additional information for the four new Activity Codes (grant types) that will be used to facilitate the new application and award process.

New Application Structure for NIH-Funded International Collaborations (NOT-OD-25-155)

ActiveNIHSep 12, 2025

Issued September 12, 2025, this notice provides additional information on the agency's new process for handling foreign components, as NIH announced in NOT-OD-25-104 that the agency would not issue awards for proposals that include subawards to foreign entities. Under the process described in NOT-OD-25-155, competing applications that include one or more foreign components must submit to a Notice of Funding Opportunity (NOFO) that supports a complex mechanism activity code, including two new international project 'parent' activity codes that NIH is creating: PF5 for grants and UF5 for cooperative agreements.

Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects (NOT-OD-25-130)

ActiveNIHJul 18, 2025

Issued July 18, 2025 as a follow-up to NOT-OD-25-104. This updated guidance creates an alternative, short-term approach for existing grants and cooperative agreements involving human subjects research (e.g., clinical trials and clinical research) with foreign sites. The alternative approach involves removing a foreign sub-award from the primary award and having it issued as a foreign supplement award.

Updated NIH Policy on Foreign Subawards (NOT-OD-25-104)

ActiveNIHMay 1, 2025

Issued May 1, 2025. Prospectively updates NIH policies and practices for utilizing foreign subawards. Per the notice, 'NIH is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant. This new award structure will include a prime [with independent linked awards] that will allow NIH to track the project's funds individually while scientific progress will be reported collectively by the primary institution under the Research Performance Progress Report.' NIH anticipates implementing the new award structure by no later than September 30, 2025, prior to Fiscal Year 2026. The policy continues to support direct foreign awards and plans to expand this policy to domestic subawards in the future, for consistency.

Safeguarding Your Research (Canada)

ActiveFederalOct 1, 2022

A Government of Canada website (October 2022) that provides guidance and resources for researchers engaging in international research.

Trusted Research (United Kingdom)

ActiveFederalJan 1, 2019

A reference (2019) that can be utilized for advice and guidance which supports the integrity of the system of international research collaboration.

Appropriations Law (Section 1340 of Public Law 112-10), aka the "Wolf Amendment"

ActiveNASAJan 1, 2011

The 'Wolf Amendment' (2011) prohibits participation, collaboration, or coordination bilaterally with China or any Chinese-owned company on any NASA project at the prime or subrecipient level. NASA clarified in a September 2022 presentation that the agency defines a 'Chinese-owned company' as any company owned by China, or any company incorporated under the laws of China, and that Chinese universities and similar institutions are considered to be incorporated under the laws of China and therefore the funding restrictions apply.

Legislation & Congressional Activity

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CHIPS Act Sec. 10631: Requirements for Foreign Talent Recruitment Programs

ActiveFederalAug 1, 2022

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.

CHIPS Act Sec. 10334: Online Resource

ActiveNSFAug 1, 2022

Directs [NSF] to develop an online resource to inform institutions and researchers of security risks and best practices and explain Foundation research security policies.

CHIPS Act Sec. 10337: Responsible Conduct in Research Training

ActiveNSFAug 1, 2022

Expands the requirement for RCR training to include faculty and other senior personnel on [NSF] awards and expands the scope of such training to include mentoring training and training to raise awareness of research security risks as well as Federal export control, disclosure, and reporting requirements.

Related Comparisons

Disclosure Requirements Comparison

Compare how each agency handles biosketch and current/pending disclosure.

Training Requirements Comparison

Compare training and certification requirements across agencies.

MFTRP Certification Comparison

Compare malign foreign talent recruitment program certification requirements.