Dear Colleagues:
UCLA faculty are regularly recognized as distinguished researchers attracting global attention. Foreign talent recruitment programs are mechanisms sometimes used by foreign countries to legitimately recruit U.S. researchers. These programs may include positions or activities with compensation (cash or in-kind), research funding, complimentary travel, honorific titles, and promises of career advancement. Of recent concern, however, has been the proliferation of Malign Foreign Talent Recruitment Programs (MFTRPs), which encourage, or even require, unethical or criminal behavior, and/or contain requirements that may pose a conflict of interest, conflict of commitment, or loss of intellectual property to their U.S. home institution and federal research awards.
Guidance
Definitions of foreign talent recruitment programs and MFTRP can be found at OSTP’s Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs as well as on the UCOP Foreign Talent Recruitment Programs web page, which includes a short video on this topic.
The CHIPS and Science Act of 2022 prohibits federal employees, contractors, and awardees from participating in MFTRPs. Most federal agencies, including NSF, DOE, DOD, and NASA already require covered individuals1 to certify that they are not a member of a MFTRP in their bio sketch and current and pending (other) support submissions. I expect that other federal agencies will adopt similar requirements in the future. Covered individuals who are currently members of a MFTRP are ineligible to participate in federally funded research and development projects.
NSF
In addition to requiring updated certifications every time a bio sketch and current and pending support report is submitted, effective June 07, 2025, the NSF requires all Principal Investigators (PIs) and Co-Principal Investigators (Co-PIs) named on one or more active awards made on or after May 20, 2024, to certify annually that they are not participating in a MFTRP. Impacted PIs and Co-PIs will be prompted to complete the MFTRP certification upon logging into Research.gov. FAQs and examples are available on the NSF Research Security web page.
DOD
DOD established a decision matrix and factors for assessing a covered individual’s affiliations, collaborations, and funding; risk mitigation plans may be needed if DOD identifies any of these factors in its security review. Prior participation in a MFTRP usually requires mitigation measures to be implemented by the institution.
Prior Approval
Faculty governed by Academic Personnel policies on Outside Activities and Conflicts of Commitment (APM-025 and APM-671) must receive prior approval to participate in any foreign talent recruitment program (not just MFTRPs). Requests to participate in what is determined to be a MFTRP will likely be denied as participation creates unmanageable conflicts and potential disqualification from participating in U.S. federally sponsored research.
If you have questions, please contact UCLA Research Security at Research.Security@research.ucla.edu.
Sincerely,
Roger M. Wakimoto
Vice Chancellor for Research & Creative Activities
1 Covered individual is defined as 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. Agencies may also define other individuals as covered persons as appropriate and consistent with their mission.