Funding Agency Requirements

Pursuant to the CHIPS and Science Act of 2022, National Security Presidential Memorandum 33 (NSPM-33), and prior legislation, the National Science Foundation (NSF), the Department of Defense (DoD), and the Department of Energy (DoE) have implemented specific requirements aimed at combating foreign influence, especially as pertains to Malign Foreign Talent Recruitment Programs (MFTRPs). 

The National Science Foundation (NSF) revised Proposal and Award Policies and Procedures Guide (PAPPG), effective May 20th, 2024, states the following:
  • Eligibility. Individuals who are a current party to a MFTRP are not eligible to serve as a senior/key person on an NSF proposal or on any NSF award made after May 20, 2024. 

  • Certifications required for senior/key personnel. Each individual identified as senior/key person on any proposal submitted on or after the above date must certify that they are not a party to a MFTRP (1) prior to proposal submission and (2) annually thereafter for the duration of the award.

  • Certifications required for the institution. Additionally, the institution must certify that all individuals identified as senior/key personnel have been made aware of and have complied with their responsibility to certify that the individual is not a party to a MFTRP.

Beginning August 9, 2024, the Department of Defense is prohibited from providing funding to or making an award of a fundamental research project proposal in which a covered individual is participating in a malign foreign talent recruitment program or to a proposing institution that does not have a policy addressing malign foreign talent programs pursuant to Section 10632 of the CHIPS and Science Act of 2022.
On June 7th, 2019, the DOE issued the DOE Order 486.1 that prohibits DOE employees, contractors, and certain subcontractors from currently or in the future participating in foreign talent recruitment programs of countries determined sensitive by DOE, such as China’s Thousand Talents programs.