Office of Research Integrity and Assurance

Foreign Talent Recruitment Programs

What is a Foreign Talent Recruitment Program (FTRP)?

A Foreign Talent Recruitment Program (FTRP) is a program organized, managed or funded by a foreign government to recruit researchers or students in targeted fields. Participation in a FTRP involves any activity that includes compensation or promised compensation (e.g., cash, complimentary travel, honorific titles, access to resources) provided by a foreign country or an entity affiliated with a foreign country.

A malign foreign talent recruitment program (MFRTP) is a talent program that is, a) sponsored by a foreign country or entity of concern, and b) requires one or more problematic actions of the participant.

The CHIPS and Science Act of 2022 (Public Law 117-167) directs federal research sponsors to maintain policies that:

  • Require covered individuals (individuals designated as senior/key persons on a proposal) to disclose all participation in FTRPs, and
  • Prohibit recipients of federal support from participating in any malign FTRPs (MFTRPs).

George Mason and ORIA are committed to fostering and safeguarding our community’s open scientific collaboration with scholars around the world. At George Mason, investigators must disclose any participation in any foreign talent recruitment program (FTRP) as they do with all outside activities. ORIA and OSP have established processes to support MFTRP review and certifications for all federal proposals. For more information and resources on FTRPs, please read below.

A FTRP is considered malign when two conditions are met: (1) It is associated with a country of concern:
  • People's Republic of China (including Hong Kong & Macao)
  • Democratic People's Republic of Korea
  • Russian Federation
  • Islamic Republic of Iran
and (2) It requires an individual to do one or more of the following:
  • Engage in the unauthorized transfer of IP, materials, data, etc.
  • Recruit others to join the activity
  • Establish a laboratory or company
  • Accept a position or appointment with a foreign country or entity
  • Not have the ability to terminate the contract or agreement
  • Limit their capacity to carry out research or work
  • Apply for/receive funding from foreign funding agencies
  • Omit acknowledging George Mason or the sponsoring federal agency
  • Not disclose participating in the activity
  • Have a conflict of interest or conflict of commitment
Not all talent recruitment programs are malign, and it can be difficult to determine at first glance whether an activity may meet the definition of a MFTRP. If you are considering or are already engaged in an activity and have concerns or questions about whether or not it may be considered malign by the government, please reach out to [email protected] for assistance and guidance.
Section 10632 of the CHIPS and Science Act of 2022 requires that every federal agency have MFTRP certifications in place. NSF was the first agency implementing this requirement, and guidance from other agencies is forthcoming. To ensure the university’s compliance with federal law and guidance, Mason has implemented a Malign Foreign Talent Recruitment Program certification for ALL federal proposals that includes a review of key personnel Biosketches, Current and Pending and COI disclosures. More information on implementation and agency-specific requirements can be found on the OSP pages below. Resources will be updated as agency requirements are revised. OSP Pre-award Research Security Compliance MFTRP Security Check Process
Mason resources on disclosure and review process can be found below: MFTRP Security Check Process MFTRP Security Check process FAQs MFTRP Information Sheet OSP Pre-award Research Security Compliance OSP Current and Pending/Other Support Requirements Overview
Consistent with Section 10632(d) of the Chips and Science Act, a foreign talent recruitment program typically does not include the following international collaboration activities, so long as the activity is not funded, organized, or managed by an academic institution or a foreign talent recruitment program on the lists developed under paragraphs (8) and (9) of Section 1286(c) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232):
  • Routine scientific exchanges (e.g., invited lectures, peer review panels, international conferences)
  • Publishing written materials regarding scientific information
  • Research that involves the open exchange of information aimed at advancing international scientific understanding
  • Advising and writing recommendations for foreign students enrolled in higher education
  • Activities sponsored by the United States (e.g., serving as a government appointee to a joint scientific fund)
  • Participating in international technical, multilateral scientific, and standards setting organizations (e.g., the International Telecommunications Union)
  • Participating in a Fulbright Commission program
  • National or international academies or professional societies that produce publications in the open scientific literature
  • Taking a sabbatical, serving as a visiting scholar, or engaging in continuing education activities such as receiving a doctorate or professional certification at an institution of higher education
  • Receiving awards that enhance the prestige of your sponsoring federal research agency (e.g., Nobel Prize)
  • Other international activities approved by the sponsoring federal research agency
Before entering into an agreement or engaging in an activity with an entity or institution associated with a country of concern (defined as China, Iran, North Korea, Russia), please reach out to [email protected] for assistance. Our team is here to support and assist your international collaborations. We can help you review proposed agreements and activities, assess risk, provide participation guidance, and work with you on next steps as needed.
NSF Research Security Page (scroll down for MFTRP guidance and resources) NPSM-33 Implementation Guidance Appendix: Definitions OSTP Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs
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