KR Certification Update May 2024

Memo sent to RAC 5/3/2024

Dear Colleagues,

The CHIPS and Science Act of August 9, 2022 requires federal research funding agencies to establish a policy by August 9, 2024 requiring:

  • Each Covered Individual (as defined below) listed in a proposal to certify at the time of proposal submission, and annually for the duration of the award, that they are not a party to a Malign Foreign Talent Recruitment Program (MFTRP) as defined in the Act.
  • Covered Individuals to disclose participation in Foreign Talent Recruitment Programs (FTRP) contracts, agreements, or other arrangements.
  • Certification by the institution that such individuals have been made aware of the requirement.

Per the CHIPS and Science Act, the term ‘‘Covered Individual’’ means an individual who— 

(A) contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and 

(B) is designated as a covered individual by the Federal research agency concerned.

Principal Investigators and Senior/Key Personnel are normally considered Covered Individuals.

The National Science Foundation (NSF) is implementing these certification requirements as of May 20, 2024, and other agencies will introduce similar requirements in the near future. 

In order to comply with these and other upcoming requirements, the University of Maryland, Baltimore (UMB) must update guidance as to who must certify proposals in Kuali Research (KR) before the proposals are submitted by Sponsored Programs Administration (SPA) to the sponsor and also add a new question to the Investigator Certification Questionnaire for Principal Investigators and Senior/Key Personnel to answer.

All proposals submitted into routing on/after May 10, regardless of the sponsor, must adhere to this updated guidance. 

Specifically, as of May 10, 2024, all UMB Principal Investigators AND UMB Senior/Key Personnel must be listed on the KR Proposal Development record and must complete the Investigator Certification Questionnaire before a proposal can be routed for UMB approval and submission to the sponsor. 

If a proposal was submitted for routing prior to May 10th but is returned or recalled on or after May 10th, the Senior/Key Personnel will be required to complete the Investigator Certification Questionnaire before the proposal can be submitted back into routing. 

Proposals already in progress and not returned or recalled will not be impacted.

Principal Investigators: There is no change in process for Principal Investigator Certification.

Senior/Key Personnel: Those individuals named in the proposal as Senior/Key Personnel must answer the Investigator Certification Questionnaire for each proposal. Certifications by Investigators and Senior/Key Personnel cannot be delegated to another party. UMB employees must only be added to a proposal as Senior/Key Personnel from the employee table in KR. UMB students do not need to be added to KR, or certify in KR, unless they are listed in the proposal as Senior/Key Personnel. Non-UMB employees can be added as Senior/Key Personnel and will not be required to certify in KR. Subaward organizations must certify for their own employees in accordance with federal guidelines.

In addition, another Investigator Certification question has been added and Principal Investigators and Senior/Key Personnel will be asked to certify that they are not participating in a Malign Foreign Talent Recruitment Program, as defined by the CHIPS and Science Act.

Additional Information can be found in the following links, including definitions for Principal Investigators, Senior/Key Personnel, and Malign Foreign Talent Recruitment Program:

UMB’s Research Security Website
OSTP Memo to Federal Research Agencies
NSF Proposal & Award Policies & Procedures Guide (PAPPG) NSF 24-1
DOD Memo, Policy for Risk-Based Security Reviews of Fundamental Research
National Security Presidential Memorandum 33 (NSPM-33)
Key Persons and KR Proposal Roles

We appreciate your assistance in ensuring UMB’s compliance with sponsor policies and procedures.

Any questions should be directed to my attention.

Thank you,


Jill A. Frankenfield
Associate Vice President, Sponsored Programs Administration
University of Maryland, Baltimore