Other Support and Foreign Influences

National Aeronautics and Space Administration (NASA)

UPDATE: Effective October 1, 2024, NASA requires the use of Common Forms for biosketch and current and pending (other) support in proposal submissions for grants or cooperative agreements. For awards issued after October 1, if Common Forms were not previously provided by the applicant, NASA will reach out prior to issuing the new award to request biosketch and current and pending (other) support in the Common Forms format. The biosketch form and current and pending form are available for download on NASA’s Grants Policy and Compliance website. Once completed, the investigator certifies that the information is current, accurate and complete, as well as that they are not a part of a Malign Foreign Talent Recruitment Program (MFTRP). UCOP Ethics, Compliance and Audit Services (ECAS) provides detailed guidance and resources for researchers on what is considered a Foreign Talent Recruitment Program and a Malign Foreign Talent Recruitment Program.

NASA has published a table of NASA Pre-award and Post-award Disclosure Requirements indicating what needs to be disclosed, where, and when.

Below is a summary of specific NASA guidance related to the reporting of current and pending support from domestic and foreign sources. Please Note:

  • Those typically required to report are PIs and Co-PIs (regardless of level of effort), as well as Co-Is proposing effort of 10% or more on the project, collectively referred to by NASA as “Covered Individuals”.
  • NASA funding organizations may designate other personnel categories as Covered Individuals on a project-by-project basis, therefore review the notice of funding opportunity (NOFO) to confirm who must provide current and pending support information.

NASA requires full disclosure of current and pending support except for contract proposals. Full disclosure of current and pending support includes engagement with and support from domestic and foreign sources. The October 2024 NASA Grant and Cooperative Agreement Manual (GCAM) indicates each Covered Individual listed in a NASA grant or cooperative agreement proposal is to submit current and pending support with a proposal submission and provide updates in annual progress reports.

At proposal stage, NASA requires Covered Individuals at the prime applicant and any proposed subaward provide a list of Current and Pending support for all proposals, active projects and in-kind contributions in accordance with NSPM-33 guidance:

  • Active projects, or projects with ongoing obligations, from whatever source irrespective of whether such support is provided through the proposing organization or is provided directly to the individual.
  • Any proposal that is being considered for funding from a potential funding organization (including this proposal) irrespective of whether such support is provided through the proposing organization or is provided directly to the individual.
  • Consulting activities when any of the following scenarios apply:
    • The consulting activity will require the senior/key person to perform research as part of the consulting activity;
    • The consulting activity does not involve performing research, but is related to the senior/key person’s research portfolio and may have the ability to impact funding, alter time or effort commitments, or otherwise impact scientific integrity; or
    • The consulting entity has provided a contract that requires the senior/key person to conceal or withhold confidential financial or other ties between the senior/key person and the entity, irrespective of the duration of the engagement.
  • Contracts associated with participation in programs sponsored by foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs.
  • Direct or indirect support that is funded by a foreign government-sponsored talent recruitment program, even where the support is provided through an intermediary and does not require membership in the foreign government-sponsored talent recruitment program.
  • All current and pending in-kind contributions that directly support the individuals’ research and development efforts with an estimated dollar value of $5,000 or more and that require a commitment of the individual’s time.
    • In-kind contribution may include but is not limited to: real property; laboratory space; equipment; data or data sets; supplies; other expendable property; goods and services; employee or student resources.

Covered Individuals are also strongly encouraged to refer to the table of NASA Pre-award and Post-award Disclosure Requirements for detailed disclosure requirements.

Failure to disclose: If Berkeley discovers that a Covered Individual has failed to disclose reportable information in Current and Pending Support, then Berkeley SPO is required to notify NASA within 30 calendar days per the award’s terms and conditions. Upon receipt of the information, NASA will consult with Berkeley as necessary and take appropriate action.

Please note that the NASA Restrictions on Funding Activities with China continues to apply to all NASA funded projects.

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