Foreign Talent Recruitment Programs

Participation in FTRP often involves academic or research affiliations with foreign institutions, financial or other in-kind support for a U.S. researcher’s program, and commitments of time and resources from the U.S. researcher.

Malign Foreign Talent Recruitment Programs (Prohibited for UF Researchers)

As part of the national discussion of inappropriate foreign influence on U.S. research, many federal sponsors have cited FTRP as posing a particular threat to the U.S. research community. Certain researchers (“covered individuals”) are now prohibited from participating in a federally funded research and development project if they are currently participating in a “malign foreign talent recruitment program” (MFTRP) (CHIPS & Science Act of 2022). Read the UF Research directive regarding these programs here. 

An MFTRP is a “program, position or activity” that:

1.     is sponsored by a Foreign Country of Concern;
2.     involves compensation or remuneration; and
3.     contains problematic obligations or activities.

“Covered individuals” are defined by the CHIPS and Science Act of 2022 as those who:

• contribute in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and
• are designated as a covered individual by the Federal research agency concerned.

Compensation or remuneration includes in-kind compensation, such as:

• research funding
• promised future compensation
• complimentary foreign travel
• things of non de minimis value
• honorific titles, including visiting or honorary
• career advancement opportunities or other considerations.

Problematic obligations or activities include:

• 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;
• being required to recruit trainees or researchers to enroll in such program, position, or activity;
• 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;
• being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;
• 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;
• 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;
• being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal agency sponsoring the research and development award;
• being required to not disclose to the Federal agency or employing institution the participation of such individual in such program, position, or activity; or having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award.

Reminder of UF Disclosure Requirements

Prior to accepting any affiliation with another institution that requires a commitment of time or resources, whether full-time, part-time, or voluntary, and irrespective of whether the affiliation is compensated or not, UF employees must disclose the activity to the University and receive approval. This includes participation in foreign talent recruitment programs (FTRP) or other affiliations/appointments at another institution. See coi.ufl.edu to review UF’s Conflict of Interest Policy and access details regarding how to disclose.

Regulatory Background

CHIPS and Science Act of 2022

OSTP Guidelines