Federal agencies, including the USDA, NSF, NIH, and DOE, have recently enacted new research security policies requiring mandatory training and enhanced documentation for key personnel involved in federally funded research. These changes aim to prevent foreign interference and improve transparency.

🛡️ Mandatory Research Security Training

• NSF, USDA, and DOE now 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)
• Other agencies are expected to announce similar requirements in the coming months.  For more information, see: Research Security Training
• The NIH notice on research security implementation issued September 11, 2025, has been rescinded.  NIH is expected to release updated guidance in the coming months.

📄 Enhanced Documentation Requirements (NSF)

• Effective October 10, 2025, NSF will conduct risk assessments on proposals and awards to identify potential nondisclosures 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 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 agencies are adopting Common Forms for Biosketch and Current and Pending (Other) Support to standardize disclosure practices across agencies, as mandated by NSPM-33.
• NSF and NIH require use of these forms for all applications and Research Performance Progress Reports (RPPRs) (as of May 25, 2025).
• Researchers must disclose:
  • All professional appointments and affiliations
  • All current and pending sources of support, including foreign entities
  • Any participation in foreign talent programs
• NIH will continue collecting three agency-specific elements—Personal Statement, Contributions to Science, and Honors—via a separate Biographical Sketch Supplement.
• All senior/key personnel must use SciENcv to generate digitally certified PDFs and link their ORCID ID to their eRA Commons profile.

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.