NSF SECURE Center
Research Security Briefing

Effective June 3, 2026, the U.S. Department of Agriculture (USDA) issued Deviation #2026-USDA-0001-F, revising its General Terms and Conditions for Federal Awards (originally effective December 31, 2025), with key changes to research security provisions.

 

The June 3 revisions include the following updates to definitions in Section 10.0, Research & Development, Science & Technology:

• Covered individual: Previously the Terms and Conditions (T&Cs) included referenced “individual(s) employed to work on the award”, e.g., with respect to training certification. The revised T&Cs replace “individual" with “covered individual.”  However, whereas other agencies specify this term refers to senior/key personnel, USDA states that the term refers to an individual who meets the following criteria:

Contributes to the scientific development or execution of research, carried out as part of this USDA award, through any of the following responsibilities:

Directing the overall scientific direction of the project; Designing or critically evaluating key experiments or methodologies; Interpreting primary research data or results; Serving as a primary or senior author on publications resulting from the project; Exercising direct supervisory authority over research personnel working on the research project; or Generating, handling, or having direct access to primary, pre-publication research data; proprietary materials; or critical, specialized methodologies essential to the project’s execution.”

 

Of note, this term can include undergraduate, graduate, or postdoctoral students. As such, USDA provides greater specificity while continuing to expand the definition of covered individual under specified conditions, including “any other individual USDA specifically identifies in writing as a covered individual.”

 

• Foreign individual: Now explicitly includes lawful permanent residents within the category of non-foreign persons.

• Foreign ownership, control, or influence (FOCI):Replaces the prior "U.S. citizen or entity subject to FOCI" definition, reframing FOCI in terms of risk to non-public research information.The revised “FOCI” is defined as:

“a situation where the degree of ownership, control, or influence over the recipient or a covered individual by a foreign person or foreign entity that is a citizen or permanent resident of; representing; organized, chartered, or incorporated under the laws of; or otherwise substantially connected to a foreign adversary or foreign country of concern such that a reasonable basis exists for concluding that compromise to that foreign person or foreign entity of non-public research, development, scientific, or technological information associated with the Federal award may result.”

• Foreign interest: A new addition to Section 10.0 that had previously appeared as a footnote, defined as "a foreign person or foreign entity,".

 

Additional revisions include updates to terms and conditions pertaining to:

• 10.6 Research Security Training

  • In the revised T&Cs, the completion of research security training is required for each “covered individual working on the award,” rather than “each individual employed by the recipient to work on the award.” The training requirement is annual. Certification can be made either by the institution or the covered individual on their own behalf. Regarding timing, per the T&Cs, “RST must have been completed either at the time of application, where applicable, or within the 12-month period immediately preceding the commencement of work on the award,” rather than the time of proposal as implemented by other federal agencies.

• 10.7 Foreign Ownership, Control, or Influence (FOCI) by a Country of Concern

  • The T&Cs previously indicated the following: By accepting an award from USDA, the recipient institution is certifying that “they are not currently, and will not in the future, enter into any subawards, contracts, or other agreements, or otherwise provide any form of benefit (material or non-material) through either funded or unfunded work to any foreign person, foreign entity, U.S. citizen, or U.S. entity, that is subject to FOCI by a FCOC or another foreign adversary.”

The revised T&Cs include language specifying that this term applies for the period of performance of the federal award and affects agreements “reasonably related to the federal award” In addition, the institution must certify that it, and any covered individuals, are not subject to FOCI and report subsequent discovery of this status within 5 days.

• 10.8 Disclosures

  • The revised T&Cs specify that “covered individuals” must complete and certify Common Forms (i.e., Biosketches and Current and Pending (Other) Support) in SciENcv, as opposed to “all employees of the recipient who work on the research award.”

​Similarly, the recipient must provide supporting documentation for activities involving foreign entities reported as Current and Pending (Other) Support for “covered individuals”, “including copies of contracts, grants, or any other agreements specific to foreign appointments, employment with a foreign entity, or participation in a foreign talent recruitment program (FTRP)”. Per the revised T&Cs, by accepting the award, the recipient is certifying that they have reviewed the supporting documentation for compliance with USDA’s terms and conditions.

• 10.9 Malign Foreign Talent Recruitment Programs (MFTRPs)

  • The revised T&Cs specify that “covered individuals” must certify to their non-participation in MFTRPs via the Common Forms, rather than “any individual employed to work on the research award.”

  • The revised T&Cs specify that , the recipient is certifying that no covered individuals have participated in an MFTRP within the past 10 years.The previous version of Section 10.9 did not indicate the specific mechanism for recipients to complete this certification.The revised version still includes the requirement for recipients to certify non-participation in MFTRPs – a variation from shorter timeframes adopted by other federal agencies.