COMPLIANCE CHATTER

The Malign Foreign Talent Program Participation Policy

UConn has introduced a new Malign Foreign Talent Program Participation Policy. This policy establishes the framework for researchers to comply with the CHIPS and Science Act of 2022, in which the National Science Foundation, Department of Defense, and other federal funding agencies prohibit sponsored research personnel from participating in Malign Foreign Talent Recruitment Programs (MFTRPs).

What is an MFTRP?

A talent program requiring one or more problematic actions and having problematic sponsorship (CHIPS and Science Act of 2022, 42 U.S.C. § 19232). A detailed approach to the definition is available here.

What You Need to Know

Why It Matters: This policy is designed to protect the integrity of research by regulating participation in foreign talent programs that could potentially pose security risks.

Who It Affects: Anyone involved in federally-funded international research projects is impacted. The policy refers to these individuals as "covered individuals." See the full definition of a "covered individual" in the policy text.

What Steps to Follow: All individuals listed in proposals to Federal Research Agencies must certify they are not involved in Malign Foreign Talent Recruitment Programs.

Various offices and individuals are responsible for specific tasks:

Responsible Party	Required Task(s)
Principal Investigator	Ensure all Covered Individuals on the award understand their responsibilities and report any concerns to Research Security Services for review.
Covered Individual	Certify as part of the proposal submission that they are not currently participating in, nor will they participate in, a Malign Foreign Talent Recruitment Program. Such certification must be renewed annually for the duration of the award.
Office of the Vice President for Research (OVPR)	Collect COI reporting forms from Covered Individuals.
Office of the General Counsel	Advise Research Security Services with the review of activities that may be considered Malign Foreign Talent Recruitment Programs.
Faculty Consulting Offices	Review consulting requests for involvement in a Malign Foreign Talent Recruitment Program and will facilitate the review of any requests of activities occurring in or with an entity of a maligned foreign country in coordination with Research Security Services
Research Security Services	Review activities that may be considered Malign Foreign Talent Recruitment Programs in coordination with all relevant offices.
Sponsored Program Services	Collect certifications from Covered Individuals on a per-proposal basis and for funded awards, confirm on an annual basis and will certify to Federal Agencies that this policy exists and, if required, that Covered Individuals are compliant with this policy.

Review the full policy for detailed guidance on compliance and approvals.

Malign Foreign Talent Program Participation Policy

Have questions or need assistance?

Contact the Office of the Vice President for Research (OVPR).

UConn Storrs/Regional OVPR

UConn Health OVPR

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