Members:

A Feb 23, 2001 Amendment to the OSS Guidebook (Office of Space Science) of
NASA, replaces Section 1.6, Proposals Involving Personnel from Non-U.S.
Institutions with the Export Control Guidelines that invoke ITAR
regulations.  This new amendment would seem to indicate that all proposals
submitted under BAAs to this office will need to accept ITAR regs or request
exemptions/exceptions at the time the proposal is submitted.  I have two
questions:

Has anyone dealt with this at the proposal stage yet?

How are you interpreting Section 2.3.10, subpart (vii) of the Guidebook, as
it relates to the prohibition of NASA funds used for research efforts of a
non-U.S. "institution?"  Would it be allowable to pay a non-U.S.
"consultant" if not connected to a foreign "institution?"

Thanks for you help.

Joanne K. Altieri
Director
Contract Negotiations and Research Compliance
University of Kansas and
University of Kansas Center for Research, Inc.
2385 Irving Hill Road
Lawrence, KS  66045-7563
Phone:  785/864-7462
Fax:  785/864-5049
E-mail:  xxxxxx@ukans.edu

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