New Research Security Certification and Other Important Information for PIs and Senior/Key Persons
Dear Principal Investigators and Senior and Key Personnel,
Please see important information below concerning a new certification requirement for individuals applying for Department of Defense (DoD) funding; background relevant to all researchers; and a refresher regarding comprehensively sanctioned countries and regions.
New Mandatory Certification for PIs and Senior/Key Persons Applying for DoD Funding
Starting on August 9, 2024, a new certification in Rascal will be required for all principal investigators and senior/key persons submitting proposals to the DoD. The certification takes only a minute or two to complete. Investigators will be certifying that they are not participating in malign foreign talent recruitment programs (Malign FTRPs), in compliance with U.S. law. After August 9, DoD proposals may not be finalized in Rascal or submitted to DoD until all senior and key persons have completed the new certification.
The definition of Malign FTRP is complex. If you are not certain whether an engagement meets the definition, please contact [email protected] for a consultation. More information is also available on the University’s research security webpage.
Background on Malign FTRP Certification Requirement
As we have communicated previously, the CHIPS & Science Act of 2022 (“CHIPS Act”) and Columbia policy prohibit federally funded senior and key persons from participating in any Malign FTRPs. By definition, Malign FTRPs must involve China, Iran, North Korea, or Russia (which the CHIPS Act has defined as “Foreign Countries of Concern”), or entities in those countries, and must meet certain other criteria. Researchers who participate in Malign FTRPs are not eligible to serve as senior/key persons on federally funded projects.
The CHIPS Act requires researchers participating in federally funded projects to certify that they are not participating in Malign FTRPs. Funding agencies are implementing this requirement on a rolling basis. For example, NSF has implemented it through SciENcv as of May 2024; NIH has stated it will implement SciENcv in May 2025. DoD, however, has not yet implemented a certification mechanism. For this reason, the separate Rascal certification is required for individuals applying for DoD funding.
Comprehensively Sanctioned Countries and Regions
Finally, we also take this opportunity to remind all researchers that in addition to the Malign FTRP restrictions for Foreign Countries of Concern listed above, the U.S. government also has comprehensive sanctions against the following countries and regions:
Any researcher planning a project that involves a comprehensively sanctioned country or region should contact [email protected] as soon as possible for guidance.
Thank you for your attention to these important topics.
Naomi Schrag, JD
Vice President for Research Compliance, Training, and Policy
William Berger
Assistant Vice President, Sponsored Projects Administration