The National Institutes of Health (NIH) has implemented a new requirement in all RPPR’s requiring all Senior/Key Personnel to upload a signed certification confirming that they are not participating in a Malign Foreign Talent Recruitment Program (MFTRP) at the time of submission.
To assist the USC research community with this new requirement, the Department of Contracts and Grants (DCG) has developed a standard certification template to assist investigators in certifying when preparing RPPR submissions.
Why This Matters:
This new requirement is part of expanded federal research security efforts designed to increase transparency around foreign affiliations and talent recruitment programs.
As part of the RPPR process, NIH now requires confirmation that Senior/Key Personnel are not participating in MFTRP, which are programs that may involve compensation, appointments, or other incentives from certain foreign entities in exchange for activities that could conflict with U.S. research integrity or federal funding obligations.
Failure to provide accurate certifications could result in:
- Delays in RPPR submission or processing.
- Compliance issues with federal sponsor requirements.
- Potential civil or criminal liability for misrepresentation.
NIH requires investigators to certify that the information provided regarding their support and affiliations is current, accurate, and complete, and that they are not participating in a malign foreign talent recruitment program at the time of submission.
What Investigators Need to Do:
For NIH awards requiring RPPR submission, each Senior/Key Personnel must complete the attached MFTRP certification form and upload to section G.1 of the RPPR report as a flattened PDF file.
Departments should coordinate with the Principal Investigator and all Senior/Key Personnel early in the RPPR preparation process to ensure certifications are completed before internal routing and submission.
If there are questions or concerns regarding participation in MFTRP, the party should reach out to Ben Bell in the Office of Ethics and Compliance to resolve those.
Additional Helpful Resources:
- NIH RPPR Instruction Guide
- NIH RPPR Overview
- NIH Notice: NOT-OD-26-018
- Protecting Your Research: What You Need to Know About Malign Foreign Talent Programs
Questions?
If you have any questions about MFTRP certification, please contact Ben Bell. For questions regarding the RPPR process, please feel free to contact your DCG Officer.