Malign Foreign Talent Recruitment Programs

NIH has issued a notice (NOT-OD-26-018) about upcoming changes to the Biosketch and Other Support forms, which includes a warning that:

Effective January 25, 2026, individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP) are not eligible to serve as a senior/key person on an NIH grant or cooperative agreement.

The only thing I can recall from NIH that specifically addresses a foreign “Talent” program is the reference to the Chinese Thousand Talents in the context of concern about corruption in NIH peer review. A report from the HHS Office of Inspector General was issued back in 2020 because:

In August 2018, NIH Director Dr. Francis Collins raised concerns that peer reviewers-who review applications for NIH extramural grants and have unique access to confidential information in those applications-were, in some cases, inappropriately sharing this information with foreign entities.

To make this short, the Full Report (PDF) mentioned the Chinese Thousand Talents Plan extensively.

China’s Thousand Talents Plan China’s central government announced the Thousand Talents plan in 2008. One aspect of the plan provides financial incentives for Chinese scientists living abroad to return to China.13 According to NIH, access to foreign intellectual property is key to a scientist’s selection for the Thousand Talents program. In a 2018 meeting of NIH’s Advisory Committee to the Director, NIH identified several concerns related to talent recruitment programs such as the Thousand Talents plan:

• undisclosed foreign financial conflicts;
• undisclosed conflicts of commitment; and
• peer review violations, including the inappropriate sharing of confidential information.

In 2023, I commented on the ongoing barrage of admonishments from NIH about the “integrity of peer review” and had apparently forgotten about the earlier report. Because from that 2020 report we learn:

Between February 2018 and November 2019, NIH confirmed 10 cases involving peer reviewers who were stealing or disclosing confidential information from grant applications or related materials and who also had undisclosed foreign affiliations.49 Two of these 10 cases involved peer reviewers who were selected for China’s Thousand Talents program. The breaches of confidentiality included disclosing scoring information, sharing study section critiques, and forwarding grant application information to third parties. In some of these instances, reviewers shared confidential information with foreign entities.

About six cycles of review across the entire NIH and they found 10 cases, two of which were in China’s Thousand Talents programs. I linked a number of articles reporting on the issues of proper reporting of foreign funding and review confidentiality, many of which claimed unfair targeting of Chinese or Chinese-American PIs.

The new admonishment about “malign foreign talent recruitment” links to the CHIPS and Science Act which is now US law. In SEC. 10638 42 USC 19237.DEFINITIONS we find

The term “malign foreign talent recruitment program” means—(A) any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual

emphasis added. I emphasize this part because people are already freaking out on the socials about the first part where it would seem to cover some pretty conventional stuff related to seminar visits, conference participation that is reimbursed, etc. The list of individual actions in exchange for said compensation includes unauthorized transfer of intellectual property, being required to recruit other scientists into the program, taking lab or faculty appointment in the foreign country in a way that violates terms of US Federal grants, being prohibited from leaving the foreign program, conducting overlapping research improperly, being required to take funding from that foreign government’s agencies, omitting acknowledgement of US Federal funding… this all seems like bog standard bad stuff that PIs who are funded by the NIH realize they are not supposed to be doing. Particularly when it comes to failing to report other sources of research funding, effort commitments and/or influences on what can and cannot be published.

The law goes on to add any program sponsored by a foreign country of concern, academic institutions or any foreign talent recruitment programs on a naughty list developed under a 2019 National Defense act.

As always, the Devil is in the details, and when it comes to this sort of thing my viewpoint is mostly related to who is doing the deciding, on what basis, what is the scope of the actual problem and to what extent does this become a witch hunt against a certain class of NIH funded PI.

When an Inspector General report finds 10 instances of peer review shenanigans of which only two individuals are seemingly involved with a malign foreign talent recruitment program, well I’m not sure focusing on that is getting the job done. Far better to work on detecting actual review shenanigans instead of imagining that additional pre-meeting training sessions is going to do anything. If shenanigans are rare, I’m presuming they are not being done out of broad ignorance but rather by intentional bad actors. So catch them!

This new warning and the upcoming changes to the Other Support are, I suppose, designed to make applicant institutions wary? And perhaps themselves to start policing any foreign entanglements of their Professors a bit better. Starting with making an example of any PIs who have been a little too slippery with disclosures about their foreign lab/funding entanglements? Some of those newsy pieces which cast some PIs as the victims of anti-China bias do drop a crumb or two suggesting failures of proper reporting.

I dunno….even if the real motivation is the typical academic scientist’s drive to sustain (and grow) laboratory funding/staff and productivity this becomes a sort of FAFO situation. NIH is pretty clear about reporting Other Support, overlapping funding, etc. Always has been as far as I know. Institutional effort/commitment reporting may vary in specifics across time and space but I’ve always found my institutions to be pretty clear when they need me to report conflicts of commitment/effort, etc.