An important new research policy on Foreign Talent Recruitment Programs (RE0003) was issued by the UT System in August 2024. All University of Tennessee, Knoxville researchers—especially those who lead or participate in federally funded sponsored projects—must familiarize themselves with the new policy and their associated responsibilities.
UT Policy RE0003 responds to new U.S. government regulations designed to address growing concerns about malign foreign influence on the U.S. research ecosystem. To thwart coordinated foreign efforts to access and exploit the expertise and intellectual properties in U.S. universities, the CHIPS and Science Act of 2022, as well as additional guidance from the White House Office of Science and Technology Policy (OSTP) in 2024, created new restrictions and requirements that you will encounter if you lead or participate in federally funded sponsored projects. These restrictions and requirements are described in Policy RE0003, as well as in additional guidance prepared by the UT System.
These new restrictions and requirements require you to disclose your participation in foreign talent recruitment programs (FTRPs) and malign foreign talent recruitment programs (MFTRPs). If you participate in MFTRPs, you are prohibited from applying for or receiving federal funding for sponsored projects.
Please be aware that the federal government has prosecuted U.S. researchers for failing to disclose their participation in (M)FTRPs. Accordingly, choosing to over-report rather than under-report your international activities in the UT outside interest disclosure (OID) system is encouraged. There is no penalty for disclosing an international activity that is subsequently determined not to qualify as participating in an (M)FTRP.
What You Need to Know
All UT researchers must understand:
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The definitions of and distinction between a FTRP and a MFTRP, as described in RE0003.
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Your obligation to disclose your participation in FTRPs and MFTRPs in the UT OID system.
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If you participate in MFTRPs, you are prohibited from applying for or receiving federal funding for sponsored projects.
FTRPs recruit researchers from U.S. universities like UT to work for foreign governments, including but not limited to universities and colleges supported by foreign governments. FTRPs often provide some form of compensation, which might include: cash or in-kind compensation; promised future compensation; research funding; complimentary travel; items exceeding de minimis value; or other non-cash benefits such as honorific titles or career advancement opportunities.
MFTRPs are a subset of foreign talent recruitment programs that are both sponsored by a country of concern (specifically China, Iran, North Korea or Russia) or a banned entity and impose certain requirements or obligations of concern to the federal government. Researchers are strongly encouraged to review the additional guidance developed by the UT System, which provides detailed instructions on how to identify an MFTRP.
Participation in both types of programs must be reported to UT, through the standard OID process, and to federal agencies, as required by each federal agency’s standard forms.
What You Need to Do
All UT researchers must:
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Disclose in the UT OID system all your international activities that may qualify as participation in FTRPs or MFTRPs, consistent with the definitions of FTRP and MFTRP in UT Policy RE0003.
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Ensure that if you participate in FTRPs, you disclose these activities in federal research proposals and awards as required by federal agencies (e.g., in the BioSketch Common Form, SciENcv, annual reports, etc.).
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Certify your non-participation in MFTRPs in federal research proposals and awards, when required by the federal government.
Frequently Asked Questions
In most instances, this would not constitute a reportable activity under the umbrella of FTRP. Participating in international conferences involving “open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law” are not FTRPs, unless they involve entities or programs on the lists named in Policy.
Regardless of its classification as a FTRP, this activity must be disclosed on the UT outside interest disclosure (OID) form, in the question about a non-UT entity paying for travel.
A：No, only interests/activities in the previous or expected in the upcoming 12 months need to be included on your UT OID form. Also, the federal government guidance specifies the prohibition applies to current and/or ongoing participation.
However, the guidance also states that Agencies may apply mitigation and management measures to address past participation. If a federal sponsor requires such measures, ORIED’s Division of Research Administration (DRA) will be notified, and you will be contacted, accordingly. If you are contacted directly by an Agency, please contact DRIA immediately.
A：The FTRP Policy and underlying Office of Science & Technology guidance apply when foreign countries are recruiting talent, not when the US is recruiting foreign talent. However, in some instances, the students who are applying to come to UT for their studies may be classified as FTRP participants, and therefore, subject to Policy requirements.
In addition to FTRP concerns, keep in mind that certain projects (e.g., export-controlled) and sponsors (e.g., NASA) have additional requirements. DRIA can help navigate this before the student is included on a research project that might have additional requirements. In most cases, they will not be allowed to participate in Department of Energy projects, due to DOE Directive 486,1A.
We encourage faculty to do their due diligence in evaluating students and any external support they may have. If any questions arise, please contact DRIA.
A：A Fulbright scholarship is not a FTRP. However, any foreign support that is not processed through UT should be disclosed on your UT OID form.
A：From the UT host (e.g., faculty, staff) standpoint, OSTP FTRP Guidelines and UT Policy state that “advising a foreign student enrolled at an institution of higher education” is not a FTRP, unless they are involve entities or programs on the lists named in Policy.
If they will be working on federally-funded projects, contact DRIA before the student begins work on the project, to advise on the specific situation.
Additional resources about FTRPs can be found here:
If you have questions about whether your international activities meet the definition of participation in an FTRP or MFTRP, or if you need help understanding your disclosure obligations, reach out directly to Jane Burns (janeburns@utk.edu) or Scott Canner (scanner2@utk.edu).