Federal Implementation of Research Security Policies

🛡️ Mandatory Research Security Training

• NSF, USDA, DOE, and NIH require all principal investigators and senior/key personnel listed in proposal and award documents to complete research security training within 12 months prior to proposal submission.
• This training covers topics such as cybersecurity, foreign influence, proper disclosure practices, and conflict of interest/commitment.
• Training requirements are currently in effect for:
  • Department of Energy (DoE)
  • United States Department of Agriculture (USDA)
  • National Science Foundation (NSF)
  • National Institutes of Health (NIH)
• NASA will begin requiring Research Security training after August 5, 2026. 
• Other federal agencies are expected to announce similar requirements in the coming months.  For more information, see: Research Security Training

📄 Enhanced Documentation Requirements (NSF)

• As of October 10, 2025, NSF began conducting risk assessments on proposals and awards to identify potential non-disclosures or foreign influence.
• Proposers and recipients must maintain supporting documentation for:
• Foreign appointments
• Employment with foreign institutions
• Participation in foreign talent recruitment programs
• Current and pending support from foreign entities.

🚫 Restrictions on Foreign Talent Recruitment Programs

• Individuals involved in Malign Foreign Talent Recruitment Programs (MFTRPs) are prohibited from serving as senior/key personnel on federal proposals or awards.
• Annual certifications through Research.gov are now required for PIs and Co-PIs, with plans to expand this to all key personnel.
• For more information, see: Foreign Talent Recruitment Programs

📑 Disclosure Requirements in Biosketch and Current and Pending Support

• Federal research agencies have adopted the Common Forms for the Biographical Sketch and Current and Pending (Other) Support to standardize disclosure practices across agencies, as required by NSPM‑33 and the CHIPS and Science Act. These forms are now required by NSF, NIH, NASA, DOE, and USDA (including NIFA) for all senior/key personnel.

All senior/key personnel must:

• • Some agencies require SciENcv to generate digitally certified Common Forms.
  • Link and ORCID iD to SciENCv (and to eRA Commons for NIH).
  • Personally certify that the information is complete and accurate.
  • Certify that they are not participating in a Malign Foreign Talent Recruitment Program (MFTRP).

These agencies require researchers to disclose:

• • All professional appointments and affiliations, domestic and foreign (paid or unpaid).
  • All current and pending sources of support, including foreign, domestic, federal, non-federal, and in-kind contributions.
  • Any participation in foreign talent recruitment programs, including those sponsored by foreign governments.
  • Any resources or commitments necessary to carry out the proposed research, regardless of whether they involve monetary support.

These updates reflect a coordinated federal effort to align with the CHIPS and Science Act of 2022 and National Security Presidential Memorandum-33 (NSPM-33), reinforcing the integrity of U.S. research against foreign threats.