The National Science Foundation (NSF) has issued Important Notice No. 149 outlining major updates to research security policies in alignment with the CHIPS and Science Act of 2022 and NSPM-33. These changes impact all NSF-funded proposals and awards and are effective October 10, 2025.
Key Updates Include:
Research Security Assessments & Documentation
- NSF may conduct risk assessments of proposals/awards for nondisclosures.
- Proposers/recipients must retain documentation for all foreign appointments, talent programs, and current/pending support.
Research Security Training Must be Completed by Oct. 10, 2025
- All parties listed as senior/key personnel must complete research security training within 12 months prior to proposal submission.
- To fulfill this requirement the Office of Culture Ethics and Compliance (OCEC) has added a 70-minute course entitled “Research Security Training” that is now available through Trojan Learn. If you are currently identified as a PI or Co-PI on an NSF award, please expect a notification from Trojan Learn assigning the course to you. For general information regarding the Research Security Training course, please visit this link.
Malign Foreign Talent Recruitment Program (MFTRP) – Prohibited
- Individuals involved in an MFTRP may not serve as senior/key personnel on NSF proposals/awards (effective May 20, 2024).
- Annual certifications required via Research.gov for PIs and Co-PIs (expanding soon to all key personnel).
Action Required by USC Faculty and Research Admins with NSF Funding:
For any USC Faculty or Staff with current NSF Funding or who expect to submit proposal to NSF, it will be important to:
- Complete your Annual certifications required via Research.gov for PIs and Co-PIs. For more information, please check out this link.
- Disclose and retain documentation for all foreign appointments, talent programs, and current/pending support.
- Ensure Senior/Key Personnel complete approved research security training in TrojanLearn.
- Ensure that no senior/key personnel are involved with MFTRP’s.
For questions, please contact the Office of Culture, Ethics and Compliance at compliance@usc.edu.