As a Georgia Tech researcher, it’s essential to understand foreign talent recruitment programs and reporting now required by federal agencies. The U.S. Government is concerned that participation in a foreign talent recruitment program could lead to undisclosed conflicts of interest, inappropriate transfer of federally funded research, export control violations, and intellectual property theft.
Quick Links
Overview
Many countries use talent recruitment programs for legitimate purposes of attracting researchers in certain fields, and many programs utilize legitimate means of attracting talent, including offering research fellowships and grants as an incentive to relocate. However, there is a distinction between “foreign talent recruitment programs” and “malign foreign talent recruitment programs.”
Though any country can sponsor a foreign talent recruitment program, the U.S. Government is particularly concerned with programs affiliated with China, North Korea, Russia, and Iran.
Note – A researcher may be participating in a foreign talent recruitment program because of the activities that they are performing, regardless of whether their activities are associated with a formal program name.
Reporting
All Georgia Tech employees who participate in foreign talent recruitment programs must disclose their participation to Georgia Tech. All covered individuals must also disclose their participation to the sponsor.
Georgia Tech prohibits any covered individual from participating in a malign foreign talent recruitment program and requires all covered individuals to comply with individual sponsor policies regarding foreign talent recruitment programs and malign foreign talent recruitment programs.
The CHIPS and Science Act of 2022 requires that covered individuals, including senior and key personnel, certify that they are not part of a malign foreign talent recruitment program in the proposal submission and annually thereafter. The CHIPS and Science Act also prohibits research and development awards from being made for any proposal in which a covered individual is participating in a malign foreign talent recruitment program.
Beginning May 2024, individuals identified as senior/key personnel on any National Science Foundation (NSF) award must certify that the individual is not a party to a malign foreign talent recruitment program before proposal submission and annually thereafter.
Other federal agencies will adopt this certification requirement over time.
Definitions
Definition of a Covered Individual
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
Designated as a covered individual by the federal research agency concerned – CHIPS and Science Act
Anyone paid on or participating in a federal project is a Covered Individual, and the agencies reserve the right to expand this definition.
Definition of a Foreign Talent Recruitment Program
Effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position).
Definition of a Malign Foreign Talent Recruitment Program
Includes any foreign-state-sponsored attempt to acquire U.S. scientific-funded research or technology unethically or unlawfully through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States.
Source: Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs
FAQs
Q: Which employees are covered by Georgia Tech’s Foreign Talent Recruitment Programs Policy?
A: Anyone who receives a paycheck from Georgia Tech is covered by this policy, as well as anyone who works on a federally sponsored project at Georgia Tech.
Q: How do I know which elements of Georgia Tech’s Foreign Talent Recruitment Programs Policy apply to me?
A: As a starting point, please consult the simple chart below. If you're uncertain about your role and how it fits, please ask! Refer to the contact information in the “Additional Questions” section below. Compliance experts are happy to work with you to ensure the security of you and the Institute.
| Must disclose to the Institute participation in FTRPs, including MFTRPs | Must disclose to the sponsor their participation in FTRPs | May not participate in an MFTRP and must attest to the sponsor accordingly | |
| Employee (anyone who receives a paycheck from GT) | X | ||
| Covered Individual (anyone who is federally funded) | X | X | X |
Q: How do I know if the entity contacting me is a foreign talent recruitment program or not?
A: Please consults the Office of Science and Technology Policy’s definitions of FTRPs and MFTRPs. However, you should contact Research Security so a compliance expert can help you assess the communication and navigate associated interactions.
Q: I am already engaged in a foreign talent recruitment program. How do I know if it is malign?
A: Disclose your participation in the program via the Conflict of Interest (CoI) Reporting system and a compliance expert will work with you to make that determination.
Q: How do I know whether to disclose an international activity to Georgia Tech?
A: Disclose all international activities to Georgia Tech through the CoI reporting system.
Additional Questions
Contact coi@gatech.edu if you have questions about reporting, or Research Security if you have questions about whether a program you are currently participating in—or considering participating in—could be considered a foreign talent recruitment program.
Disclosure to federal agencies and Georgia Tech is critical concerning foreign talent recruitment programs, and researchers should err on the side of transparency.
