Pre-Award Research Security Compliance

• 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 (C&P) and COI disclosures.
  • Biosketch and C&P forms using the Common form template or created in SciENcv contain the MFTRP certification.
  • If the sponsor does not require C&P and Biosketch forms, key personnel must complete the Internal MFTRP certification form.
  • All documents associated with MFTRP certifications must be prepared as early as possible to facilitate proposal review. Late documents may result in proposals not being submitted.
• Federal Agency MFTRP Requirements – Overview Matrix
• Federal agencies are requiring 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 Review Process

NASA China Certification Review Process

Biosketch/Current and Pending Sponsor Requirements

Mason Pre-Award MFTRP certification form

Mason NIH Annual RPPR MFTRP certification form

Background

• Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234) requires Federal agencies to implement research security training (RST) requirement at the time of PROPOSAL submission.
• To meet the federal requirement, George Mason University has adopted the SECURE Center’s condensed version of NSF’s RST module, and has included university-specific resources and information. NSF, NIH, DOE, DOD, USDA, and NASA all recognize completion of the SECURE Center’s condensed module as compliant with their RST requirements.
• All researchers at Mason are required to complete research security training on an annual basis.
• The training takes approximately 60 minutes to complete. It is available in MasonLeaps following the directions below:
• Log in to MasonLeaps.
  • Search for “Research Security Training,” OR
  • Click the direct link (after logging in): Research Security Training
• For more information on Research Security Training at Mason, you may visit the ORIA Research Security Program website.
• For subrecipients, all subrecipient key personnel must also complete training at their institution and provide certificates demonstrating completion of training.  If a consultant is named as key personnel, they may take the training on the NSF website and provide the completion certificate. 

Agency Requirements

•  Research Security Training is required by most federal agencies in order to submit proposals, with more agencies rolling out this requirement in the future. All covered individuals (senior/key personnel) listed in a research application must complete training prior to proposal submission.
• Covered individuals are defined as “an individual who (A) contributes 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 from a Federal research agency; and (B) is designated as a covered individual by the Federal research agency concerned.”
• A quick reference chart of key agency dates is below. More charts detailing agency-specific RST requirements can be found at NSF SECURE Center and COGR websites.
• Requirements and definitions vary by federal agency. It is important to review your sponsor’s specific requirements for research security training and to ask your college pre-award research administrator, OSP, or the research security team ([email protected]) for guidance if you have questions.

Agencies require the individual and institution to certify that training has been competed prior to proposal submission. OSP and ORIA recommend that PIs submitting federal proposals ensure that research security training is completed by all covered individuals as soon as possible so as not to delay proposal submission. 

OSP/ORIA Business Process

• OSP/ORIA Research Security Training Compliance business process

DoD implemented new guidelines to evaluate risk and establish risk mitigation measures for fundamental research projects.  Under these guidelines:

• Researchers’ eligibility for DoD funding may be impacted or require mitigation if they have certain international collaborators or co-authors.
• Equipment from certain international organizations may be prohibited on DoD project.

For more information, contact [email protected] or visit GMU Office of Research Security

DOD Matrix to Inform Fundamental Research Proposal Mitigation Decisions