Other Support and Foreign Influences
National Aeronautics and Space Administration (NASA)
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 all Covered Individuals at the prime and any proposed subaward institution to provide a list of Current and Pending support for all proposals, active projects and in-kind contributions in accordance with NSPM-33 guidance.
All Covered Individuals should also refer to the latest version of NASA Grant and Cooperative Agreement Manual to ensure compliance.
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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