The National Science Foundation (NSF) has implemented a new annual certification requirement. New questions have been added to the University of Tennessee, Knoxville’s DASH Research Conflict of Interest (COI) disclosure module to help researchers comply with this new requirement.
NSF Annual Certification
Effective June 7, 2025, NSF requires Principal Investigators (PIs) and co-PIs to annually certify their non-participation in malign foreign talent recruitment programs (MFTRPs). PIs and co-PIs named on NSF awards will see pop-up messages in research.gov with instructions on how to certify. Since May 2024, NSF has required similar certification on SciENcv documents submitted with proposals.
As a reminder, individuals participating in MFTRPs are not eligible to serve as senior/key personnel or covered individuals on federal research proposals or awards. For more information, see UT guidance on foreign talent recruitment programs (FTRPs).
Additional DASH Research COI Questions
New questions have been added to the DASH Research COI module to guide the disclosure of outside interests that may require further evaluation to ensure that UT researchers are in compliance with federal law and policy for research security.
These new questions also help UT researchers identify outside interests that must be disclosed to sponsors like NSF and to certify with confidence when required.
The new questions include:
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Are you an applicant or a participant party to a foreign talent recruitment program?
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Do you have an active startup package from another organization?
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Do you have a startup company based on intellectual property licensed from any other entity besides this institution?
Please ensure that your disclosure is up to date and accurately reflects all outside interests, including any participation in FTRPs or MFTRPs. If all responses are “no,” you do not need to update your disclosure until otherwise necessary.
If you cannot certify your non-participation in MFTRPs or have questions about the outside interest disclosure process, contact Scott Canner (scanner2@utk.edu or 865-974-2187) or Jane Burns (janeburns@utk.edu or 865-974-3526).