United States Research Security Standards

The United States (US) has implemented research security measures that impact Canadian researchers seeking American funding. It is important that researchers understand the different research security requirements established by the following US government funding agencies.

• National Institutes of Health (NIH)
• Department of Defense (DoD)
• National Science Foundation (NSF)
• Department of Energy (DoE)
   

The measures established by these agencies are guided by 2021 National Security Presidential Memo-33 (NSPM-33) and the subsequent 2022 Guidance to federal agencies for implementing NSPM-33, issued by the Office of Science and Technology Policy. These measures are also reflective of requirements set out in the 2022 CHIPS and Science Act.

Researchers are encouraged to consult with their US partners on any US institution-specific requirements beyond those identified for the funding agencies below.

Please contact the Research Security Team (RST) via the VPRI Contact listed below if you have questions or require assistance.

The specific steps researchers must take to ensure compliance with research security requirements will be included in the funding opportunity information.

See United States Research Security Definitions for detailed definitions and for information about the requirements set out by the funding agencies.
 

Applicable to All US Agencies

‘Covered Individuals’ (see US Research Security Definitions) will need to certify that they are not an active participant in a malign foreign talent recruitment program (MFTRP) at time of proposal submission, and annually thereafter, for the life of the award. They will also need to disclose participation in all foreign talent recruitment programs (FTRPs). This regulation is effective as of May 20, 2024, for NSF and August 9, 2024, for all other externally sponsored awards (Federal and non-Federal).

Proposals submitted with past MFTRP participation (up to August 9, 2022) may warrant additional scrutiny and require mitigation measures. Contact the Research Security Team for more information.

See United States Research Security Definitions for detailed definitions of MFTRP and FTRP.
 

National Institutes of Health (NIH)

The NIH requires the disclosure of all sources of research support, ‘foreign components’, and financial conflicts of interest for senior/key personnel on research applications and awards.

NIH defines a ‘foreign component’ as the performance of any significant element or segment of the project outside the United States either by the grantee or by a researcher employed by a foreign institution, whether or not grant funds are expended. Activities that would meet this definition could include the following.

• Collaborations with investigators at a foreign site anticipated to result in co-authorship
• Use of facilities or instrumentation at a foreign site
• Receipt of financial support or resources from a foreign entity
• The involvement of human subjects/or animals
• Extensive foreign travel by grantee project staff for the purpose of data collection, surveying, sampling, and similar activities (Note: Foreign travel for consultation is not considered a ‘foreign component’)
• Any activity that may impact on US foreign policy through the involvement of grantee project staff in the affairs or environment of the foreign country
   

While awards directly to foreign/non-US-based institutions may not require additional explanation, NIH determines foreign components on a case-by-case basis.

For more information, please see Foreign Interference and Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components.
 

Department of Defense (DoD)

The DoD has a detailed risk-based security review process for any funding opportunities. Where possible, DoD will seek to mitigate any research security risks that may be uncovered during the review process. Such security risks may include the following.

• Indicators of participation in a foreign talent recruitment program (FTRP)
• Indicators of funding from a Foreign Country of Concern (FCOC) or a FCOC connected entity
• Patents or patent applications resulting from US government funded research that were filed in a FCOC or on behalf of FCOC connected entity before filing on in the US
• Affiliation with an entity on the US Bureau of Industry and Security (BIS) Entity List
   

Beginning August 9, 2024, DoD is prohibited from providing funding to or making an award of a fundamental research project proposal in which a covered individual is participating in a malign foreign talent recruitment program (MFTRP) or to a proposing institution that does not have a policy addressing malign foreign talent programs. For more information, see Security Considerations for Foreign Talent Programs.

For detailed information on DoD requirements, including a list of MFTRPs and foreign institutions confirmed to be engaging in activities of concern, please see Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education.
 

National Science Foundation (NSF)

As mandated by the CHIPS and Science Act, the NSF has established the Research Security and Policy Office to identify potential security risks. NSF requires universities applying for NSF funds to disclose agreements and gifts from China and other Foreign Countries of Concern (FCOCs). Likewise, the NSF requires individuals to submit various disclosures, including appointments, affiliations and current and pending support from external funding sources.

For more information, please see Research Security at the National Science Foundation.
 

Department of Energy (DoE)

DoE prohibits employees, contractors, and certain subcontractors, including university researchers funded by DoE contracts or subcontracts, from currently or in the future participating in Foreign Government-Sponsored Talent Recruitment Programs of a Foreign Country of Risk (analogous to a Malign Foreign Talent Recruitment Program (MFTRP)).

In addition, DoE restricts participation in Other Foreign Government Sponsored or Affiliated Activities of a Foreign Country of Risk. Disclosure of pending and current participation is required. Foreign nationals who wish to work on DoE-funded fundamental research projects at universities must receive an approval from DoE before they can work on research projects. As defined by DoE, anyone who is not a US citizen by birth or naturalization is a foreign national.

For more information, please see Office of Science Laboratory Policy Science and Security and the DOE O 486.1A, Foreign Government Sponsored or Affiliated Activities Frequently Asked Questions.

Individual academic institutions / corporations in the US may also have their own research security requirements to abide by in addition to government requirements. If available, these requirements can generally be found on the institution’s website under ‘Research Security’.

In addition, be mindful of the US sanctions / restricted entity lists when applying for international grants. Helpful resources include the US Bureau of Industry and Security (US BIS) Lists of Parties of Concern and the Office of Foreign Assets Control (OFAC) Sanctions List Search.