Dear Colleagues,
We are writing to let you know of a forthcoming National Science Foundation (NSF) policy to help ensure that you can comply with its requirement once effective. This policy may impact your collaborations with certain foreign institutions.
Once effective, the policy will:
- Prohibit senior / key personnel from collaborating with the restricted entities (or their employees) on NSF-funded projects. The restricted entity lists can be found on Appendix A of the NSF announcement.
- Prohibit senior / key personnel from holding an appointment or position with the restricted entities for the duration of the NSF award.
- Prohibit senior / key personnel from receiving research support from the restricted entities for the duration of the NSF award.
- Prohibit NSF appropriated funds from being used for grants, contracts, other transactions or other assistance to an organization if the purpose is to conduct research in collaboration with the restricted entities.
- Require senior / key personnel and the Authorized Organizational Representative (AOR) to certify to compliance with these prohibitions at the time of proposal submission.
Notably, the restricted entity lists include a significant number of universities and research institutions located in China.
Though this policy is not yet in effect, NSF intends to implement this policy as of October 1, 2026.
What This Means for You:
NSF-funded researchers should take the following actions:
- Review anticipated collaborations to ensure they will comply with these new requirements once they become effective.
- Consider that these prohibitions will impact collaborations with former University researchers (such as students and postdoctoral fellows) who join a restricted entity after departing the University. Senior / key personnel will be prohibited from collaborating with the restricted entities and their employees on NSF-funded projects even if the project began when the collaborator was affiliated with the University.
- Assess whether they hold any appointments or positions with, or receive research support from, any of these restricted entities. Appointments and positions will be considered within the scope of the policy whether they are paid or unpaid, and whether they are full-time, part-time, or voluntary.
As communicated in prior guidance, researchers should:
- Contact the Export Control Officer (Nicole Porter; export@rochester.edu) and the Research Security Officer (Joe Doyle; researchsecurity@rochester.edu) for restricted party screening assistance on any foreign appointments, positions, or research support; and
- Contact the Export Control Officer (Nicole Porter; export@rochester.edu) prior to initiating a research collaboration with a foreign institution, or to assess any existing collaborations.
If you have further questions about this new policy, please contact the University’s Research Security Officer (Joe Doyle; researchsecurity@rochester.edu).
Thank you for your attention to this important matter.
Joe Doyle
Research Security Officer
Office of the Vice President for Research
Phone: (585) 273-2827
rochester.edu | @urochester