NASA disclosures

National Aeronautics and Space Administration (NASA)

The information below is from the NASA Grant and Cooperative Agreement Manual (GCAM), NASA’s grant manual for proposers and recipients, effective October 1, 2024. 

NASA Pre-award and Post-award Disclosure Requirements 

Provides helpful reference information regarding pre-award and post-award disclosures. The table includes the types of activities to be reported, where such activities must be reported in the application, as well as when updates are required in the application and award life cycle. A final column identifies activities that are not required to be reported.

10.5 Biographical Sketches

A biographical sketch documents an individual’s qualifications and professional experience, and the information is used to assess how well qualified an individual is to conduct proposed award activities. Each senior/key person listed on a NASA grant or cooperative agreement proposal is required to submit biographical sketch disclosures with their application.

10.6 Current and Pending (Other) Support Disclosures

Current and pending (other) support information is used to assess the capacity of senior/key personnel to carry out proposed award activities and helps NASA assess any potential scientific and budgetary overlap or duplication, as well as conflicts of commitment, with the proposed project. Each senior/key person listed on a NASA grant or cooperative agreement proposal is required to submit current and pending support disclosures with their application.

10.9 Facilities, Equipment, and Other Resources

Disclose the following per the NASA Pre-award and Post-award Disclosure Requirements table:

  1. In-kind contributions with an estimated dollar value of $5,000 or more that support the research  activity for use on the project/proposal being proposed, and
  2. Postdoctoral scholars, students, or visiting scholars who are supported by an external entity, and whose research activities are intended for use on the project/proposal being proposed; and
  3. If considered F&E, current or pending participation in, or applications to, programs sponsored by foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs.

Senior/Key Persons – defined as an individual who (a) contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and (b) is designated as a covered individual by the Federal research agency concerned.

a.     NASA will designate as a covered individual any: 

  1. PI (regardless of level of effort)
  2. Co-PI (regardless of level of effort)
  3. Co-I’s proposing to spend ten percent or more of their time in any given year on a NASA-funded award.

b.     NASA funding organizations may designate additional personnel categories as covered individuals on a project-by-project basis, and these designations will be explicitly stated in all NOFOs.

Failure to disclose 

If an entity discovers that a senior/key person has failed to disclose reportable information in accordance with this section, then the entity shall notify NASA within 30 calendar days per their award’s terms and conditions. Upon receipt of the information, NASA will consult with the entity as necessary and take appropriate action.

12.1 Proposal Rejection Without Review

NASA reserves the right to reject a proposal without review for the following reasons:

If it is determined that a senior/key person failed to disclose required biographical sketch or current and pending (other) support information. 

16.16 Malign Foreign Talent Recruitment Programs (MFTRP)

1.     In accordance with the CHIPS and Science Act of 2022, covered individuals are prohibited from participating in a Federally funded research and development project if they are currently participating in a malign foreign talent recruitment program (MFTRP), and they are required to certify that they are not a party to a MFTRP. 

Definition and more information on MFTRPs. 

2.     Upon completing a biographical sketch and current and pending support form, senior/key personnel will be required to sign a certification statement reading “I also certify that, at the time of submission, I am not a party to a malign foreign talent recruitment program.” 

a.  42 U.S.C. § 19232(a)(1) requires that covered individuals submit a certification stating that they are not a party to a MFTRP annually after proposal submission for the duration of the award. As such, all NASA award recipients shall ensure that senior/key persons have certified annually that they are not a party to a MFTRP in accordance with the entity’s annual certification process. These annual certifications do not have to be submitted to NASA, but award recipients must maintain them in their award files in accordance with their record keeping policies and make them available to NASA upon request in accordance with 2 CFR § 200.334, Retention requirements for records, and § 200.337, Access to records.

3.     Upon submitting a proposal in NSPIRES, entities’ AORs will be required to certify that all senior/key persons associated with the proposal have been made aware of and have complied with their responsibility to certify that they are not a party to a MFTRP.

29.8 Post-award Biographical Sketch, Current and Pending (Other) Support, and F&E Disclosures

After an entity receives an award, senior/key persons shall disclose new activities that have arisen since submission of the proposal.  

  • Senior/key persons shall indicate that there are new disclosures in the first RPPR that is submitted to NASA after the activity has been disclosed to the entity. 
  • Senior/key persons shall indicate that a new activity has been disclosed in the “Participants & Other Collaborating Organizations” section of the RPPR. 
  • If there are new disclosures, senior/key persons must prepare, certify, and submit a revised disclosure form, or updated F&E information, with the RPPR.

34.0 Remedies for Noncompliance

If it is determined that a designated individual failed to disclose required information, such as biographical sketch, current and pending support, COI, or criminal violation information, NASA may take one or more of the following actions:

a.     Refer the failure to disclose to the NASA OIG for further investigation or to Federal law enforcement authorities to determine whether any criminal or civil laws were violated;

b.     Report the individual or entity in SAM.gov to alert other Federal agencies to the noncompliance;

c.     Take such other actions against the individual or entity as authorized under applicable law or regulations.

d.     In the event a senior/key person fails to comply with the NASA’s current and pending (other) support disclosure requirements, no enforcement action for such failure shall be applied to the entity that submitted a proposal unless:

  1. The entity did not meet the requirements of 42 U.S.C. § 6605(a)(2);
  2. The entity knew that a senior/key person failed to disclose information under 42 U.S.C. § 6605(a)(1), and the entity did not take steps to remedy such nondisclosure before the proposal was submitted; or
  3. The NASA Administrator determines that:

a.     The entity is owned, controlled, or substantially influenced by a senior/key person; and
b.     Such senior/key person knowingly failed to disclose information under 42 U.S.C. § 6605(a)(1