FAQs
Why is UCAR implementing this new certification form?
This is the direct result of a Congressional act. You will see it referenced in the NASA Procurement Information
Circular at http://www.hq.nasa.gov/office/procurement/regs/pic12-01.html Guide.
What is the effective date for this process?
Per the terms of the Act, it was effective for all funds appropriated on or after April 25, 2011. The effective date for
UCAR is at time of new proposals.
What does it mean by “the restriction does not apply to commercial items of supply needed to perform a grant or cooperative agreement"?
Commercial items of supply means if you are buying a widget from a commercial Chinese company then you are exempt from the restriction. All research and development activities must comply.
Who needs to sign a form?
Both the UCAR Principal Investigator (PI) and any named UCAR Co-PIs. Any named subrecipients must have their
AO sign a subrecipient assurance form.
Will it apply to proposals where NASA is funding UCAR directly or as the prime from a passthrough organization?
Yes, the restriction applies to all proposals whether direct, passthrough, or NASA interagency funds through NSF.
For NASA incremental interagency funds the certification form will be required at time of award.
Will this process also apply to supplemental requests on current NASA awards?
Yes, it applies to all funding whether new awards, award modifications where we have not previously certified the collaboration, and all supplemental funding requests.
What does it mean if the PI checks "yes" to involvement with China?
If the PI checks yes, UCAR may submit a proposal but a waiver will need to be granted by NASA’s Office of
General Counsel before the proposal will be funded. Any situation that involves participation with China will be reviewed by NASA on a case-by-case basis to determine whether restricted funds can be used under the circumstances. NASA Contract officers, in conjunction with NASA technical officers, shall consult with the NASA
Office of General Counsel prior to funding any NASA award that appears to include any participation with a
Chinese owned company, the Chinese government, or individuals in any way affiliated with the above.
Is the UCAR Authorizing Official (AO) signature required on every form?
If the proposal is being submitted through NSPIRES, the AO signature is not required prior to submission. The AO will “sign” the certification form when (s)he submits the proposal in NSPIRES.
When in the process is the UCAR AO signature required?
The AO’s signature may be required should NASA request a certification prior to award. NASA would request an
AO’s signature on those proposals which were submitted in NSPIRES prior to the effective date of the
Appropriations Act.
Where UCAR is the lead, is it required for the PI to have all named subrecipients complete the Subrecipient
Assurance form?
Yes, there is a separate certification for the sub recipient’s Authorizing Official to certify prior to proposal submission. In rare instances UCAR Contracts would allow the submission of a proposal without the Subrecipient’s
Assurance form. However, the Subrecipient Assurance form will need to be received prior to award. By signing the
UCAR PI Questionnaire, the UCAR PI certifies (s)he has reviewed the involvement of all collaborators working on the proposal. Regardless of whether a certification has been obtained at point of proposal the UCAR's Subcontract
Administrator will flow down the requirement to the subrecipient organization.

When we are submitting directly through NSPIRES does the PI also need to complete the hard copy form?
Yes. We need to have a definitive response on this form. This is similar to the PI disclosure procedure whereby the PI, by their signature, confirms that (s)he has performed due diligence by reviewing the involvement of all funded and unfunded collaborators working directly with UCAR. The PI is also responsible for responding to the certification question within NSPIRES.
Does the certification form need to be signed for Step 1 proposals (Notice of Intent)?
No. However, it will need to be completed prior to submitting the full Step 2 proposal.
Does the certification process apply to zero dollar collaborations where the UCAR PI may be participating on another organization ’s proposal to NASA?
The restriction still applies to zero funded collaborations when participating as an unfunded collaborator with another organization. However, UCAR will only require a signed certification form if requested by the prime awardee. UCAR will NOT require the certification for any unfunded collaborators that are participating on a UCAR led proposal.
Do all unfunded collaborators on a UCAR led proposal need to sign a similar certification?
This is not required as long as UCAR's PI signs the appropriate certifications. It is the PIs responsibility if they are working with unfunded collaborators to confirm that the individual(s) they are working with do not work for China or any Chinese-owned company, any Chinese university or individual affiliated with these.
How will we determine if UCAR Chinese visitors are allowed to participate on NASA funded projects?
If a Chinese collaborator is a UCAR employee (s)he may work on a NASA funded project. If a Chinese collaborator is an employee at other U.S. institutions or U.S. universities (s)he may work on a NASA funded project. The PI should evaluate each visiting Chinese collaborator to determine if that collaborator is restricted from working on the
NASA project.
Is collaboration with someone from a Chinese university allowable?
The restriction states NASA funds may not be used by "any company/institution incorporated under the laws of the
People's Republic of China". All Chinese universities would be incorporated under Chinese law. Therefore, collaboration with someone from a Chinese university is restricted.
How does this affect travel to China?
NASA funds awarded with FY11 funds appropriated on or after April 25, 2011, FY12 funds, and all future appropriations should not be used to cover travel expenses to China for collaborations and attendance at meetings.
Does the UCAR Travel office check for compliance?
No. The person authorized to approve travel within the lab/division/program needs to verify before signing the travel authorization that the lab/division/program is not using NASA funds on travel for a restricted Chinese visitor/collaborator/participant. This is similar to how the lab/division/program complies with the Federal Travel
Regulations (FTR) when the FTRs are incorporated in a specific award.
How does this restriction affect field programs?
UCAR may not participate in a field program conducted within the country of China using NASA funds. A Chinese collaborator may not participate in a field program if it is funded solely by NASA. However, if the field program is funded by multiple sources and the expertise provided by the Chinese collaborator can be clearly defined by a statement of work funded by a non-NASA source, they may participate. Please work with the UCAR Contracts office on a case by case basis.
Are Chinese collaborators allowed to work on community models?
If NASA has contributed funds appropriated on or after April 25, 2011 to the community model a Chinese collaborator is not allowed to work on the community model either as a funded or unfunded collaborator.
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How does this restriction affect NASA sponsored workshops and training?
Funds containing the restriction are those FY11 funds appropriated on or after April 25, 2011, FY12 funds, and all future appropriations. If NASA funds appropriated after April 25, 2011 are being used to sponsor a workshop or training, Chinese workshop participants are not allowed to attend.
Can I use NASA funds appropriated prior to April 25, 2011 to fund Chinese collaborators, travel, and workshops?
Funds appropriated prior to April 25, 2011 may be used if you clearly segregate funds received after April 25, 2011 by setting up a separate account key for those funds received after April 25, 2011.
How does this restriction apply if a workshop or activity is funded by multiple fund sources, NSF, NOAA, and NASA?
A Chinese collaborator may not participate in a workshop if the workshop is funded solely by NASA. However, if the workshop is funded by multiple sources and the content of the workshop is not specific to a NASA funded activity, such as Kepler, the collaborator may participate as long as NASA funds are not used for participant support.
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