Every researcher on a federal research proposal now certifies they are not party to a malign foreign talent recruitment program. SYSWERX finds talent programs on the public record, cites each one to where it appears, and checks it against what the researcher disclosed, so your office can ask the question first.
Federal research agencies had until August 2024 to put these certifications in place. They sit beside the disclosure of foreign appointments and support on the Current & Pending (Other) Support and Biographical Sketch forms.
Each covered individual on a federal research and development proposal certifies they are not a party to a malign foreign talent recruitment program, in the proposal and every year of the award.
The institution certifies that each covered individual it employs on the proposal was made aware of the requirement and made the certification.
Federal policy bars awards to proposals in which a covered individual is in a malign program, and asks institutions, where practicable, to keep participants off funded projects.
Under the Act, two things together make a program malign: what the researcher is rewarded for, and who sponsors it.
Cash, research funding, promised compensation, travel, honorary titles or career opportunities, in exchange for things like:
And the sponsor is China, Russia, Iran or North Korea (or an entity based there), another country the State Department names, or an institution or talent program on the Defense Department's §1286 lists.
The Act protects ordinary international collaboration. Agency policies may not prohibit:
The exception falls away when the activity is funded, organized or managed by an institution or program on the §1286 lists. A co-author abroad is not, by itself, a talent program.
Talent programs used to announce themselves. Under U.S. scrutiny, the best-known one stopped advertising, and a program name a researcher once acknowledged on a paper may now appear nowhere at all.
China's Thousand Talents Plan recruited foreign-trained scientists in the open. Then China stopped promoting it.
Reuters, August 24, 2023
The effort came back under new names and formats. Its main successor, Qiming, overseen by China's industry ministry, does not publish its awardees, is absent from central government websites, and recruits partly through headhunters' ads, including on LinkedIn.
Reuters, August 24, 2023
Recruitment widened. Provinces, cities and counties offered their own relocation packages, and in October China opened a K visa for young science and technology professionals that needs no employer invitation.
Yale Environment 360, June 10, 2025 · State Council of the People's Republic of China, in effect October 1, 2025
Whatever a program is called, the appointment and the support still belong on the Current & Pending (Other) Support. That is what the disclosure check compares.
Talent programs leave a trail: in a researcher's own profile, in the acknowledgments of their papers, and in the titles and appointments that come with them.
Under the CHIPS and Science Act, a program, position or activity that rewards a researcher (with money, funding, travel, titles or career opportunities) in exchange for things a federal award forbids, such as transferring nonpublic work, recruiting trainees, or hiding the arrangement, when it is sponsored by a foreign country of concern or by an institution or program on the Defense Department's §1286 lists.
No. Scholarly presentations, publishing, international conferences, open research exchanges and advising foreign students are protected, unless a listed institution or program funds, organizes or manages them. A co-author abroad is not, by itself, a talent program.
No. It finds talent programs on the public record, cites each one, and shows whether it was disclosed. Whether a program is malign, and what to do about it, stays your institution's call. A clean result is never a clearance.
The Act names China, North Korea, Russia and Iran, plus any other country the Secretary of State determines. Programs and institutions on the Defense Department's §1286 lists count wherever they are.
Each covered individual on the proposal: someone who contributes substantively to the project and whom the funding agency designates as covered. The institution certifies too, that its covered individuals were told and made the certification.
Talent programs are part of the disclosure NSPM-33 asks for, and the first factor of the 2026 DoW decision matrix for Defense-funded fundamental research. How SYSWERX supports NSPM-33 →
This page summarizes the CHIPS and Science Act for orientation and is not legal advice. Your sponsored programs office and counsel have the final word on what your institution certifies.
Bring a researcher you'd review anyway. We'll show where a talent program would appear, how it's cited, and the case file it produces.