Introduction

Participation in foreign talent recruitment programs (FTRPs) can involve risks that warrant careful consideration, mitigation, and–in some cases–complete avoidance. Congress, the Federal Bureau of Investigation, and other government organizations view aspects of certain FTRPs as threats to the integrity and security of the national research enterprise. The CHIPS and Science Act (the C&S Act) directs federal research sponsors to maintain policies that:

• require covered individuals to disclose all participation in FTRPs, and
• prohibit recipients of federal support from participating in any malign FTRPs (MFTRPs).

Foreign Talent Recruitment Program (FTRP) Definition

NSPM-33 implementation guidance from the Office of Science and Technology Policy provides a working definition of FTRP: An effort that is 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 full-time or part-time position). Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation.

Malign Foreign Talent Recruitment Program (MFTRP) Definition

The C&S Act provides a definition of MFTRP–essentially a talent program requiring one or more problematic actions and having problematic sponsorship. Read the full definition here, and review the red flag indicators that a Foreign Talent Program may be considered “malign” below. 

(Some) Indicators that a Foreign Talent Program may be Malign

• Unclear contract terms or obfuscation of information
• Inability to terminate the contract
• Requirement to recruit students/researchers and/or set up a fully functional lab in the foreign country
• Requirement to apply for in-country funding for projects that overlap with your US government funded projects
• Requirement to omit your Brown University affiliation or funding sources from publications
• Requirement to not disclose the activities on US grant applications
• Requirement to do anything that violates the terms and conditions of your US grant funding
• Sponsored by the government of or an entity located in a Foreign Country of Concern (currently defined as Iran, Cuba, Russia, China, North Korea)

Brown University Responsibilities under the C&S Act

1. Have a policy prohibiting Covered Individuals from participating in MFTRPs
Covered Individuals are Investigators on federal research funding. As part of the implementation of Research Security requirements, Brown is developing this required policy prohibiting MFTRP participation for federally funded researchers. Contact [email protected] to learn more. 

2. Certify on a per-proposal basis and annually
Brown must certify that Covered Individuals on federally funded research are not participating in MFTRPs and are, therefore, eligible or continue to be eligible as Investigators. Contact your OSP pre-award contact to learn more.

Your responsibilities at Brown

Until the MFTRP policy goes into effect in 2024, there are no changes to Brown researchers’ responsibilities. Brown researchers must continue to disclose Significant Financial Interests and other activities on their COI Reporting Form, which is submitted via InfoEd (see the COI in Research Policy for details). Faculty must also continue to abide by the Outside Professional Activities policy. Once the MFTRP policy goes into effect, researchers who are participating in research supported by federal awards will be prohibited from participating in a Malign Foreign Talent Recruitment Program.

For more information or to get involved, contact the Office of Research Integrity at [email protected].