/Office for Research and Innovation
Research Security

National Aeronautics and Space Administration (NASA) Research Security Guidance

The National Aeronautics and Space Administration (NASA) supports international scientific collaboration while protecting U.S. national interests and complying with statutory restrictions applicable to NASA-funded research. NASA research security requirements are implemented through the NASA Proposer's Guide, Notices of Funding Opportunity (NOFOs), NASA grant and cooperative agreement requirements, and applicable federal research security requirements.

The Office of Research Security (ORS) assists investigators throughout the NASA award lifecycle by providing guidance on disclosure requirements, international collaborations, foreign organizations, research security training, export controls, and other NASA research security requirements.

How NASA Evaluates Research Security

NASA's research security requirements focus on:

Transparency

NASA requires complete and accurate disclosure of information required by the funding opportunity, including:

  • Professional appointments and affiliations
  • Biographical Sketches
  • Current and Pending (Other) Support
  • Foreign research support and in-kind resources
  • International collaborations
  • Required certifications and research security training

Compliance with Federal Research Security Requirements

NASA has implemented federal research security requirements established under NSPM-33 and the CHIPS and Science Act, including Common Disclosure Forms, research security training for covered individuals, and certifications related to Malign Foreign Talent Recruitment Programs (MFTRPs), as applicable to NASA financial assistance awards.

Restrictions on Bilateral Activities with China

Federal law prohibits NASA from using appropriated funds for bilateral participation, collaboration, or coordination with the People's Republic of China or Chinese-owned companies under NASA grants and cooperative agreements.

The restriction applies whether the activity is funded by NASA or performed under a no-exchange-of-funds arrangement and applies to both prime recipients and subrecipients. Chinese universities are considered organizations incorporated under the laws of the People's Republic of China for purposes of this restriction. Proposals that include prohibited bilateral activities may be ineligible for award.

Important: The NASA China restriction applies to the activity, not the nationality of the researcher. A Chinese citizen who is affiliated with a U.S. institution is not automatically prohibited from participating in a NASA-funded project. The restriction generally applies to bilateral participation, collaboration, or coordination with the People's Republic of China, Chinese-owned companies, or organizations incorporated under the laws of the People's Republic of China, including Chinese universities.

Proposal Development

Before submitting a NASA proposal, investigators should ensure:

  • Biographical Sketches and Current and Pending (Other) Support are complete and accurate.
  • Foreign appointments and affiliations are disclosed.
  • International collaborations are appropriately described.
  • Required NASA research security training has been completed, when applicable.
  • Required certifications, including those related to MFTRPs, are complete and accurate.
  • Proposed collaborations comply with NASA's statutory restrictions regarding bilateral activities with China.
  • Foreign organizations and subrecipients have been reviewed for compliance with NASA requirements.

Contact ORS Before Proposal Submission If Your Project Involves

  • International collaborators or foreign organizations.
  • Chinese universities or Chinese-owned companies.
  • Foreign appointments or affiliations.
  • Foreign research support or in-kind resources.
  • Export-controlled technology, software, equipment, or technical information.
  • International data sharing.
  • Questions regarding NASA disclosure requirements or bilateral collaboration restrictions.

Award Management

During an active NASA award, investigators should consult ORS before:

  • Establishing a new international collaboration.
  • Adding a foreign collaborator or foreign organization.
  • Accepting a new foreign appointment or affiliation.
  • Receiving new foreign research support.
  • Providing foreign collaborators access to research data, software, equipment, or technical information.
  • Making significant changes affecting project personnel, disclosures, or project scope.

Depending on the activity, NASA may require updated disclosures, sponsor notification, or additional institutional review.

Post-Award Responsibilities

Research security responsibilities continue throughout the life of a NASA award.

Investigators should promptly notify ORS regarding:

  • Changes in Current and Pending (Other) Support.
  • New foreign appointments or affiliations.
  • New foreign research support.
  • New international collaborations.
  • Material changes affecting sponsor disclosures or award conditions.
  • Requests from NASA for additional documentation or clarification.

Early consultation allows the University to determine whether updated disclosures, sponsor notification, or additional institutional review is required.

Activities That May Require Additional Institutional Review

Examples include:

  • Foreign appointments or affiliations.
  • Foreign research support or in-kind resources.
  • International collaborations.
  • Collaborations involving Chinese organizations.
  • International data sharing.
  • Export control or sanctions concerns.
  • Research involving sensitive technologies.
  • Questions regarding NASA disclosure requirements or bilateral collaboration restrictions.

Activities That Are Prohibited or May Affect Funding Eligibility

Examples include:

  • Bilateral participation, collaboration, or coordination with the People's Republic of China or a Chinese-owned company under a NASA-funded grant or cooperative agreement, except where specifically authorized by law.
  • Materially incomplete or inaccurate sponsor disclosures.
  • Failure to complete required research security training or certifications.
  • Failure to comply with applicable NASA award terms and conditions.
  • Failure to comply with applicable federal research security requirements.

How ORS Can Help

ORS provides assistance with:

  • NASA disclosure requirements
  • Current and Pending (Other) Support
  • Foreign appointments and affiliations
  • International collaboration reviews
  • China bilateral collaboration reviews
  • Research security training
  • Export controls
  • Research security consultations

ORS works closely with investigators, Sponsored Programs, Information Security, and other University offices to identify research security requirements early, facilitate appropriate international collaborations, and support successful management of NASA-funded research throughout the award lifecycle.