NASA reminds all grant and cooperative agreement recipients that federal law prohibits using NASA‑appropriated funds for any bilateral participation, collaboration, or coordination with China or Chinese‑owned companies. This restriction applies to all activities under NASA awards, including those carried out by subrecipients.
Key Requirements
- No bilateral coordination, collaboration, or participation with:
- Chinese government entities
- Chinese universities
- Chinese‑owned companies
- Individuals employed by any of the above
- No direct sharing of NASA‑funded research data with these entities, including through IT systems.
- No bilateral joint publications with authors affiliated with Chinese government, university, or corporate entities.
Where This Comes From
- Institutions attest to compliance at proposal submission through the AOR certification.
- The NASA Grant and Cooperative Agreement Manual (GCAM) includes explicit language on this restriction (Section 9.4 and Appendix A).
- The statutory basis is in NASA’s annual appropriations legislation, most recently Section 526 of Pub. L. 119‑74.
Institutional Responsibilities
- Ensure all project activities comply with award terms and GCAM requirements.
- Monitor subrecipients for adherence to the restriction.
- Maintain internal controls to prevent prohibited bilateral engagement.
Consequences of Noncompliance
- Disallowed costs
- Award termination
- Referral for potential suspension or debarment
Questions
Contact your NASA Grant Officer for award‑specific guidance.