Funding Agency Requirements
Pursuant to the CHIPS and Science Act of 2022, National Security Presidential Memorandum 33 (NSPM-33), and prior legislation, many federal sponsors have implemented specific requirements aimed at combating foreign influence, especially as pertains to Malign Foreign Talent Recruitment Programs (MFTRPs).
To ensure compliance with these obligations for both individual researchers and the institution as a whole, GW prohibits all researchers currently receiving or intending to seek federal funding from participation in MFTRPs. If you are unsure if a program or offer that you have received from a non-U.S. entity constitutes a MFTRP after reviewing the posted definitions for MFTRPs, or if you have any questions, please contact the rsec
gwu [dot] edu (Office of Research Security).
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 Department of Energy (DOE) issued DOE Order 486.1 that prohibits DOE employees, contractors, and certain subcontractors from participating in Malign Foreign Talent Recruitment Programs.
DOE is mandating that Covered Individuals included on research and development (R&D) projects and/or applications with due dates on or after May 1st, 2025 must complete research security training.
- "Covered Individuals" include the PI, PD, Co-PI, Co-PD, or other individuals "who contribute in a substantive, meaningful way to the development or execution of the scope of work".
- GW is using the Collaborative Institutional Training Initiative (CITI) Program’s "Research Security Training (Combined)" module to meet this training requirement. This CITI training module will take approximately 1-1.5 hours to complete, and is a condensed version of the four-hour NSF modules which were initially required.
PIs/PDs are expected to certify that all Covered Individuals who will participate and/or have participated in the project have completed the training. PI/PD certification is completed via Current and Pending Support disclosure. Please note that proposal submission may be impacted if training completion cannot be certified by the Research Security Office.