Office of Sponsored Programs

Pre-Award Research Security Compliance

Malign Foreign Talent Recruitment Program Sponsor Requirements
  • Mason has implemented a Malign Foreign Talent Recruitment Program certification for ALL federal research proposals that includes a review of key personnel Biosketches, Current and Pending and COI disclosures.
    • If current and pending and biosketch forms are not required by the Sponsor, key personnel can instead, if preferred, complete this MFTRP certification form instead of providing Current and Pending and Biosketch forms to OSP
    • Biosketch and Current and Pending forms using the Common form template or created in SciENcv contain the MFTRP certification. Therefore, if only one of these forms is required, the MFTRP certification is completed. Key personnel will not long have to prepare both current and pending and biosketch forms if both are not required under the proposal.
    • Current and pending and biosketch documents, or the MFTRP certification, must be prepared as early as possible to facilitate proposal review. Late documents may result in proposals not being submitted.
  • OSP Authorized Organizational Representation will also have to certify that George Mason has performed due diligence in ensuring that no key personnel are involved in Malign Foreign Talent Recruitment programs.
  • Federal agencies will require all senior/key personnel on potential awards to submit updated Current and Pending (Other) Support information before making a funding recommendation. 
  • Federal agencies have also implemented annual MFTRP certification requirements.

Malign Foreign Talent Recruitment Programs (MFTRP) Information Sheet

MFTRP and NASA Research Security Review Process

Biosketch/Current and Pending Sponsor Requirements

Mason MFTRP certification form

Pre-Award Research Security Training and Compliance

Background

  • Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234) requires Federal agencies to implement research security training requirement at the time of PROPSAL submission.
  • On July 10, 2025, NSF released guidance to the Presidents of Universities and Colleges and Heads of other NSF awardee organizations related to research security training.  Effective October 10, 2025, NSF will require research security training certifications from proposers and individuals identified as senior/key personnel by the proposer. Below are the two key Research Security training compliance requirements:
    • Each individual identified as a senior/key person must certify that they have completed the requisite research security training within 12 months prior to proposal submission.  
    • the Authorized Organizational Representative (AOR) must certify that all individuals identified as senior/key personnel have completed the requisite research security training that meets the requirements within 12 months prior to proposal submission.  
  • Senior/key personnel include the individuals designated by the proposer/recipient organization and approved by the Sponsor, 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.  There are two categories of senior/key personnel: PI and CoPI and faculty associate (faculty member) or equivalent. 
  • On December 2, 2025, NIH issued NOT-OD -26-017 outlining Research Security Training Requirements for NIH.  At this time, the research security training requirement is optional. Completion of RST and the individual and institutional certifications will be effective for applications submitted for due dates on or after May 25, 2026.
    • Each covered individual (for NIH this is defined as senior/key personnel) listed on an NIH grant application must certify that they have completed RST within 12 months of the date of application submission.
    • NIH will collect the individual certification at the time of the application submission, through the Biographical Sketch in SciENcv
    • Note: NIH does not collect Current and Pending (Other) Support at the time of application based on our Just-in-Time policy.
  • NIH defines Senior/Key Personnel as the PD/PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically, these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered senior/key personnel if their involvement meets this definition. Consultants and those with a postdoctoral role also may be considered senior/key personnel if they meet this definition. Senior/key personnel must devote measurable effort to the project whether or not salaries or compensation are requested. “Zero percent” effort or “as needed” are not acceptable levels of involvement for those designated as Senior/Key Personnel..

Mason Policy – Coming Soon!

Applicability

  • Applies to current NSF and Dept of Energy proposals
  • NIH will be requiring Research Security Training completion for proposals submitted on or after May 25, 2026
  • DOD and USDA will be requiring in the near future
  • OSP and ORIA recommend that PIs planning to submit in NSF, NIH, or Dept of Energy complete this training as soon as possible so as not to delay future proposals. 

Training Course

  • The National Science Foundation’s NSF, in partnership with the National Institutes of Health (NIH), the Department of Energy (DOE) and the Department of Defense (DOD), have provided four online research security training (RST) modules as a resource to awardee organizations. Subsequently, the NSF’s Safeguarding the Entire Community in the U.S. Research Ecosystem (SECURE) Center developed an updated and condensed version of the four modules. The condensed RST module is designed to meet the government-wide RST requirement in Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234).
  • Mason Research Security Training
    • To meet the federal requirement, George Mason University has adopted the SECURE Center’s condensed version of NSF’s RST module, with university-specific resources and information included at the end. This module takes approximately 60 minutes to complete.  NSF, NIH, DOE, DOD, and USDA all recognize completion of the SECURE Center’s condensed module as compliant with their RST requirements.
    • The Course can be found by logging into MasonLeaps and searching for the title.
      • Title: Research Security Training; Provider: ORIA  
  • Once you log into MasonLeaps, you can click this direct link: Research Security Training. NOTE: you MUST be logged into MasonLeaps in order for this direct link to work.
  • For more information on Research Security Training at Mason, you may visit the ORIA Research Security Program website.

OSP/ORIA Business Process