Research Security

International engagement is a key priority for the University of Memphis as we continue to expand our global impact. This page is intended to help University of Memphis researchers navigate new research security rules that accompany international collaboration.

Research security covers a wide range of federal initiatives meant to protect academic research from being misappropriated to the detriment of national security. These initiatives have been enumerated in National Security Presidential Memorandum 33 (NSPM-33), subsequent guidance from the Office of Science and Technology Policy in 2022 and 2023, and the CHIPS and Science Act (also known as CHIPS). NSPM-33 and CHIPS require universities, including the University of Memphis, to take active measures to safeguard research. These initiatives have led to the creation of new rules and a closer review of international collaborations that may affect your work. 

As a result, a Research Security policy has been put in place to meet the requirements of the OSTP memo and other federal guidance pertaining to research security, such as the CHIPS and Science Act of 2022.

The CITI Program offers Research Security courses that provide knowledge and tools to protect against risks in the global ecosystem and undue foreign influence. These courses are relevant for faculty, institutional officlas, research administrators, and other personnel involved in research. Below are the available courses:

Research Security Training: This course covers risks and threats to the global research ecosystem, emphasizing concepts like research security, disclosure, risk management, and international collaboration.

Research Security Advanced Refresher: This is an eight-module video-based course that delves into foundational research security information and explores advanced topics. It begins with an introduction to research security and covers risk mitigation, cybersecurity, international collaborations, and more.

Contact: Please contact researchcompliance@memphis.edu for questions regarding Research Security Policy or call Ricky Tan, Director of Research Compliance at 901-678-4272. 

Notices and Updates

New Research Security Training Requirements for funding from the National Science Foundation (NSF), National Institutes of Health (NIH), Department of Energy (DOE), and Department of Defense (DoD)

The federal government has finalized new research security training requirements that apply to proposers and awardees of research funding from the National Science Foundation (NSF), National Institutes of Health (NIH), Department of Energy (DOE), and Department of Defense (DoD). These requirements are part of the broader government research security initiatives under NSPM-33 and related legislation.

What Has Changed

Beginning October 1, 2025, all individuals identified as Senior/Key Personnel on proposals and awards submitted to NSF, NIH, DOE, and DoD must complete research security training. The training addresses critical topics such as:

• Foreign influence
• Disclosure responsibilities
• Cybersecurity practices

What This Means for UofM Researchers

• Mandatory Training via CITI: All PIs and Senior/Key Personnel on proposals to NSF, NIH, DOE, and DoD must complete research security training before proposal submission (or by agency-specified deadlines).
• Training Options: (Choose One)
  • Research Security Training  – 1 Hour: Meets federal requirements and is recommended for faculty seeking a shorter option.
  • Research Security Advanced Refresher and Undue Foreign Influence Training – 2 Hours: A more comprehensive course covering the same requirements in greater depth.
• Tracking & Documentation: Completion records will be tied to the Cayuse SP proposal, consistent with how Conflict of Interest (COI) training records are tracked.

Action Steps for Researchers

1. Choose and Complete a Training Course: Access the CITI Program at https://about.citiprogram.org/. Add and complete either the Research Security Training 1-hour course or the 2-hour full course to satisfy the requirement.
2. Plan Ahead: Training must be completed prior to proposal submission for covered agencies.

Relevant Links:

• Research Security Certification Form

Need Help?

The Research Compliance Office is available to answer questions and provide support. Please contact us at researchcompliance@memphis.edu.

 

Foreign Talent Recruitment Programs

How Does the CHIPS and Science Act Affect Research and Research Security?

The CHIPS and Science Act prohibits federal employees, contractors, and awardees, including institutions, individual investigators, and other key personnel from participating in malign foreign talent recruitment programs (MFTRPs). The CHIPS and Science Act also includes provisions requiring research security training for Federal research award personnel. It requires that Federal agencies establish a requirement that each covered individual listed on an award application completes research security training and that research institutions certify that this training has been provided.

 

What are Foreign Talent Recruitment Programs and Malign Foreign Talent Recruitment Programs?

A foreign talent recruitment program is an effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a part-time or full-time position). 

A malign foreign talent recruitment program is a talent program requiring one or more problematic actions and having problematic sponsorship. Not all talent recruitment programs are malign. The UoM MFTRP Policy (RE7010) can be found here.

Starting on June 7, 2025, in accordance with the NSF Proposal and Award Policies and Procedures Guide (PAPPG), all PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov that they are not party to a Malign Foreign Talent Recruitment Programs (MFTRP). Individuals who are currently a party to a MFTRP are not eligible to serve as senior/key personnel on an NSF proposal or on any NSF award made on or after May 20, 2024. NSF is providing notification of this new requirement to impacted PIs and co-PIs.

What you need to know about completing the required MFTRP certification in Research.gov:

• The certification requirement is for PIs and co-PIs, not the organization.
• Impacted PIs and co-PIs will be prompted to complete the MFTRP certification after signing into Research.gov using the Sign In link at the top of www.Research.gov.
• PIs and co-PIs with more than one active award made on or after May 20, 2024, are only required to certify once, annually.
• Once completed, PIs and co-PIs can view their MFTRP certification response under the Academic/Professional Information section of their profile.
• NSF is working to expand the MFTRP annual certification requirement for all senior/key personnel roles at a future date.
• Frequently Asked Questions and MFTRP contract examples will be available on the MFTRP section of the Office of the Chief of Research Security Strategy and Policy website shortly.

How Do You Know if an Arrangement is a MFTRP?

A. If the arrangement is described in Box A below and has at least one factor from Box B and at least one factor from Box C, the arrangement falls within the Chips and Science Act's definition of a MFTRP.

Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue—

B. Problematic Obligations/Activities

1. engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products; 
2. being required to recruit trainees or researchers to enroll in such program, position, or activity; 
3. establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a federal research and development award; 
4. being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances; 
5. through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a federal research and development award; 
6. being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient; 
7. being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award; 
8. being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or 
9. having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and 

C. Problematic Sponsorship

And is a program sponsored by— 

1. a foreign country of concern (FCOC), currently defined as:
   • China,
   • Iran,
   • North Korea, and
   • Russia;
2. an entity based in a FCOC, whether the program is directly sponsored by the government of the FCOC; or 
3. an academic institution or a foreign talent recruitment program identified by the Department of Defense. 

Federal Government and University Expectations Regarding Disclosure and Reporting

Open scientific and scholarly collaboration between scholars from all over the world is one of the cornerstones of innovation and technological advancement, and University of Memphis remains committed to fostering such collaboration.  

However, disclosure and transparency regarding international collaborations and relationships are paramount not only to federal sponsors, but also to the University, via the University’s Conflict of Interest and Conflict of Commitment processes.

Be sure to always:

• Obtain prior approval for any research engagements or appointments with foreign entities.
• Disclose travel, housing, gifts, or other types of compensation received from any foreign entities.
• Report any support or compensation to federal sponsors as Other Support/Current & Pending Support, if applicable.

• If you work with export-controlled technologies, also check with the Office of Export Control regarding your collaboration.

 

DoD Requirements for Disclosure of MFTRP Participation

Beginning August 9, 2024, the DoD is prohibited from providing funding to or making an award of a fundamental research project proposal in which a covered individual (senior/key personnel that contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with an R&D award from a federal agency) is participating in a malign foreign talent recruitment program or to a proposing institution that does not have a policy addressing malign foreign talent program pursuant to Section 10632 of the CHIPs and Science Act of 2022. 

The University of Memphis, in accordance with federal requirements, prohibits researchers from participating in malign foreign talent recruitment programs. Individuals listed on proposals are required to certify that they are not party to a malign foreign talent recruitment program: 

1. Individuals conducting research on a federally funded award must certify annually for the duration of the award that they are not party to a malign foreign talent recruitment program. 
2. Upon submission of a proposal to a federal funding agency, the University of Memphis must certify that individuals listed on the proposal have been made aware of the requirements regarding MFTRPs and have complied with the requirements. 
3. The University of Memphis must certify annually for the duration of the award that individuals working on the award comply with the requirements regarding MFTRPs. 

It is UofM policy that researchers comply with the requirements of The CHIPS and Science Act and with all sponsor policies and certifications regarding foreign talent recruitment programs as they are developed and implemented, and that disclosures are true, complete, and accurate. 

The certifications do not apply retroactively to research and development awards made or applied for prior to the establishment of the policy by the Federal research agency. 

On June 30, 2023, DoD released Countering Unwanted Foreign Influence in Department-funded Research at Institutions of Higher Education, which includes a Policy on Risk-based Security Reviews of Fundamental Research, and a Decision Matrix with recommended factors to consider in a risk based security review of fundamental research projects for potential conflicts of interest and conflicts of commitment. 

The CHIPS and Science Act strongly encourages research institutions to seek out and collaborate with international partners. The Act expects researchers to continue to participate in the following activities without prejudice: 

1. Making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law; 
2. Participation in international conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law; 
3. Advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student, at such student’s request; and 
4. Other international activities determined appropriate by the Federal research agency head or designee.

Please contact Research Compliances with any questions or if additional information is required. 

I Want to Collaborate with an International Entity. What Should I Do?

We are here to support and assist your international collaborations.  

Before entering into an agreement or engaging in an activity with a foreign entity (government or academic institution), or if you have already received compensation from a foreign entity, contact Research Compliance at researchcompliance@memphis.edu   

Our team can help you with a risk assessment by discussing potential conflicts of interest and conflicts of commitment, reviewing the proposed agreements to identify potentially problematic terms, determine if the activity falls under the U.S. federal government’s definition of MFTRP, and work with you on next steps as needed.??? 

Frequently-Asked Questions

What are Federal Sponsor Research Security Requirements?

This page will continue to be updated as we receive more information.

Last update 08/01/2025

Some federal sponsors have upcoming Research Security requirements which must be met by all covered individuals. These requirements can include Research Security Training, ORCID iDs, and certifications or disclosures that awardees are not participating in Malign Foreign Talent Recruitment Programs.

While the UofM prohibits participation on MFTRPs, some sponsors require additional certifications or disclosures. Definitions and requirements may vary by sponsor.

Guidance, definitions, and requirements may vary by sponsor. Basic information from some of our federal sponsors is listed here for reference.

If a sponsor is not listed, it does not necessarily mean they do not have a requirement, please refer to sponsor guidance.

Definitions & Requirents by Sponsor

Dept. of Energy (DOE)

As of May 1 2025, DOE requires all covered individuals to:

• Complete all four CITI research security training modules prior to proposal submission
• Have an ORCID iD and include it in
  • Current & pending support disclosures
  • Publications resulting from awards

 

DOE Covered Individual Definition

An individual who (a) contributes in a substantive, meaningful way to the development or execution of the scope of work of a project proposed for funding by DOE, and (b) is designated as a covered individual by DOE.
DOE designates as covered individuals any principal investigator (PI); project director (PD); co-principal investigator (Co-PI); co-project director (Co-PD); project manager; and any individual regardless of title that is functionally performing as a PI, PD, Co-PI, Co-PD, or project manager.

DOE departmental elements will often expand this list of designated roles, as specified in the applicable Notice of Funding Opportunity (NOFO) and/or terms and conditions of the Federal financial assistance award. Status as a consultant, graduate (master’s or PhD) student, or postdoctoral associate does not automatically disqualify a person from being designated as a “covered individual” if they meet the definition in (a) above.

See: FAL Research Security Training Requirements for all R&D Financial Assistance Awards

DOE Malign Foreign Talent Recruitment Program Certification

The DOE requires full disclosure of foreign involvement in Current and Pending Support documentation and does not allow participation in Malign Foreign Talent Recruitment Programs.

All covered individuals must certify that they are not currently participating in a malign foreign talent recruitment program (MFTRP) within their Current and Pending Support.

 

NASA

NASA Covered Individual Definition

NASA will designate as a covered individual any PIs (regardless of level of effort), any Co-PIs (regardless of level of effort), and only Co-Is proposing to spend ten percent or more of their time in any given year on a NASA-funded award. NASA funding organizations may designate additional personnel categories as covered individuals on a project-by-project basis, and these designations will be explicitly stated in all NOFOs. See: NASA Grant and Cooperative Agreement Manual

NASA Research Security Training Requirement
Coming Soon!

NASA Malign Foreign Talent Recruitment Program Certification

Upon completing a biographical sketch and current and pending support form, senior/key personnel will be required to sign a certification statement reading “I also certify that, at the time of submission, I am not a party to a malign foreign talent recruitment program.” This certification will be required annually and kept on file.

 

National Institutes of Health (NIH)

NIH Covered Individual Definition
A “covered individual” is defined as all senior key personnel (i.e., individuals who contribute to the scientific development or execution of a project in a substantive, measurable way). This covered individual definition is applicable to SBIR and STTR applicants for purposes of the SBIR and STTR Foreign Disclosure Form.

NIH Research Security Training
Coming Soon!

NIH Malign Foreign Talent Recruitment Programs
Principal Investigators and Key Personnel on NIH awards are currently prohibited from MFTRP participation.

 

National Science Foundation (NSF)

NSF Covered individual Definition

Principal investigators (PIs) and other senior/key person seeking or receiving Federal research and development funding (i.e., extramural funding) and researchers at Federal agency laboratories and facilities (i.e., intramural researchers, whether or not federally employed), including Government-owned, contractor-operated laboratories and facilities.

See NSF Proposal & Award Policies & Procedures Guide (PAPPG)

NSF Research Security Training Requirements

Effective October 10, 2025, NSF requires senior/key personnel take Research Security Training.

NSF Malign Foreign Talent Recruitment Program Certification

Effective May 20, 2024, covered individuals must individually certify that they are not a party to a malign foreign talent recruitment program. The SciENcv Biographical Sketch and Current and Pending (Other) Support documents require each individual to certify that the information provided is accurate, current, and complete, and that they are not a party to a malign foreign talent recruitment program. Starting on June 7, 2025, all PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov that they are not party to a MFTRP.

 

USDA

USDA Covered individual Definition

Coming soon!

USDA Research Security Training Requirements

Certify that research security training has been completed not more than one year prior to the date of application and must recertify annually for the duration of the award.

USDA Malign Foreign Talent Recruitment Program Certification

Certify they are not party to a malign foreign talent recruitment program and must recertify annually for the duration of the award. Individuals are not eligible to work on USDA-supported projects if they have participated in a Malign Foreign Talent Recruitment Program within the last ten years.

See USDA Arrangements and Research Security