Participation in a foreign talent recruitment program (FTRP) warrants careful consideration, mitigation, and in some cases, complete avoidance. Malign foreign talent recruitment programs (MFTRP) can involve significant risks. Congress, the FBI, and other federal agencies view aspects of certain MFTRPs as threats to the integrity and security of the national research enterprise. Lehigh University policy prohibits University researchers who are currently participating in a MFTRP from serving as PI or key personnel on a proposal to a federal research sponsor.

The Lehigh University policy on “Foreign Talent Recruitment Programs - Restrictions and Disclosure Requirements” provides detailed definitions of both a foreign talent recruitment program (FTRP) and a malign foreign talent recruitment program (MFTRP). The federal government established these definitions in the CHIPS and Science Act of 2022. The policy also includes current information about specific federal agency requirements. Several federal agencies will require investigators to individually certify that they are not members of a MFTRP in the proposal submission and annually thereafter throughout the duration of the award.

Lehigh is committed to supporting an open and welcoming research environment. This will always include international collaboration, as well as faculty engagement in both domestic and international external professional activity. The restrictions and disclosure requirements are intended to protect Lehigh researchers’ ability to propose and manage federal research support and to assist with navigating international collaborations effectively and safely. The university’s policy is also necessary in order to comply with federal research sponsor requirements.

It is important to understand the disclosure expectations on federal proposals and to stay current on disclosing relevant outside activity when required. If you are ever unsure about whether or not an activity is permitted, or if it needs to be disclosed, you can speak with your Department Chair, Dean, or the Office of Research Integrity at nac314@lehigh.edu. Assessing whether something is a Foreign Talent Recruitment Program, particularly whether it’s malign, can be nuanced and we encourage you to focus on characteristics and behaviors.

In order to comply with institutional and federal requirements:

Complete and Update Disclosures: Complete and update federal agency and Lehigh University disclosures. Review the federal requirements and Lehigh University disclosure expectations when submitting a proposal or accepting funding.

Use the NSF-Approved Formats for the Biographical Sketch: The mandate to use SciENcv only to prepare biographical sketches and current and pending support for National Science Foundation (NSF) proposals went into effect for new proposals submitted or due on or after October 23, 2023.

You should also be aware that due to the nature of these programs, participation in a MFTRP or FTRP may:

  1. Conflict with faculty obligations outlined in Lehigh University’s Rules and Procedures of the Faculty,
  2. Require disclosure as a potential Conflict of Interest per the University’s Conflict of Interest Policy, and/or
  3. Require disclosure as a Significant Financial Interest per the University's policy on Financial Conflicts of Interest Related to Research and Sponsored Programs.

Lehigh University Office of Research Integrity - Foreign Talent Programs website

Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs, Office of Science and Technology Policy (OSTP), White House, February 2024.

Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education, Department of Defense, June 2023.

Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise, Joint Committee on the Research Environment, National Science and Technology Council, January 2021.

Threats to the U.S. Research Enterprise: China’s Talent Recruitment Plans, US Senate, Homeland Security and Governmental Affairs Permanent Subcommittee on Investigations, November 2019.