U.S. House Select Committee Releases Report on NASA’s Research Security and Enforcement of the Wolf Amendment

On May 14, 2026, the U.S. House Select Committee on the Strategic Competition between the United States and the Chinese Communist Party (the “Select Committee”) published an investigative report titled Research Security for America’s Future in Space: NASA’s Enforcement of the Wolf Amendment (the “Report”).¹ The Report examines the National Aeronautics and Space Administration’s (NASA’s) enforcement of the Wolf Amendment, a federal statute that prohibits the use of NASA funds to support bilateral collaborations with the People’s Republic of China (PRC). The Report is critical of NASA’s past compliance efforts, and particularly critical of universities, stating that “universities appear to neither adequately verify nor enforce [award] requirements, allowing researchers to engage in activities that risk placing NASA in violation of the Wolf Amendment.”²

The Report is the latest in a series of three publications issued by the Select Committee over the last nine months pertaining to the PRC’s use of U.S.-funded research and broader foreign influence concerns, including investigative reports on defense research vulnerabilities and the PRC’s activity in the Western Hemisphere, and a joint congressional letter to NASA identifying potential Wolf Amendment violations.³ The Report builds on these prior efforts and focuses specifically on the adequacy of NASA’s compliance infrastructure with respect to the Wolf Amendment.

Overview of the Wolf Amendment

The Wolf Amendment, enacted in 2011, prohibits the use of NASA funds in bilateral collaborations with the PRC.⁴ The most recent version of the Wolf Amendment states in relevant part:

None of the funds made available by this Act may be used for the National Aeronautics and Space Administration (NASA) . . . to develop, design, plan, promulgate, implement, or execute a bilateral policy, program, order, or contract of any kind to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company unless such activities are specifically authorized by a law enacted after the date of enactment of this Act.⁵

This language is incorporated into terms and conditions imposed on NASA grantees, including through an assurance and representation that grantees are required to submit, as set forth in the Grant and Cooperative Agreement Manual (GCAM):

A3. Assurance and Representation on China Restrictions Set Forth in Section 526 of PL 117-103, and All Applicable Subsequent Appropriations Acts.

By submission of its proposal, the proposer represents that the proposer is not China or a Chinese-owned company, and that the proposer will not participate, collaborate, or coordinate bilaterally with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange-of-funds basis, except to the extent NASA has notified the grant proposer that NASA has sought a waiver for such activities pursuant to Pub. L. 118-42 Sec. 526.⁶

NASA FAQs specify that “universities” are included within the definition of “China” or a “Chinese-owned company.” This interpretation—which is not directly supported by the language of the Wolf Amendment—was first incorporated into NASA’s Guidebook for Proposers in February 2021.⁷

Findings and Recommendations

To identify U.S.-PRC bilateral publications that cite funding support from NASA, the Select Committee conducted a bibliometric query and review of authorship and funding acknowledgments, examining publications from 2015 to the present. The Committee’s review flagged collaborations not just with any PRC institution, but specifically with entities within PRC’s defense research and industrial base, including the “Seven Sons of National Defense” universities, State Administration of Science, Technology and Industry for National Defense (SASTIND) co-administered schools, and laboratories designated on U.S. government restricted entity lists, such as the Bureau of Industry and Security (BIS) Entity List.⁸ Based upon this review, the Select Committee made several findings, of which the following are of particular relevance to U.S. research universities and other recipients of NASA grant funding:

• “Recent NASA-funded research publications reveal clear bilateral research relationships with Chinese entities.” The Report specifically noted publications that “explicitly acknowledge NASA funding while listing co-authors affiliated with only Chinese universities, laboratories, or research institutes.” The Report further states that “[e]ach of these cases represents a potential compliance concern that warrants further review and inquiry to determine whether the underlying research activities were conducted in accordance with federal law and the terms and conditions of the relevant NASA awards.”⁹
• “NASA publication data reveals potentially ambiguous and extralegal areas of activity under the Wolf Amendment.” These include: (1) researchers with concurrent U.S. and PRC institutional affiliations listed in their publications; (2) co-authorships with Sino-foreign joint venture universities operating under PRC law; (3) publications citing NASA funding without specific award numbers; and (4) nominally “multilateral” collaborations (which are permitted under the Wolf Amendment) that are substantively bilateral (which are not permitted).¹⁰
• “NASA has provided clear guidance to the public on what constitutes a Wolf Amendment violation,” but “lacks robust Research security capabilities and did not conduct effective post-award compliance monitoring.” The Report is also critical of university compliance frameworks, characterizing existing safeguards—including mandatory disclosure forms, export-control offices, and NSPM-33-aligned compliance programs—as “largely performative” despite calls from the government that universities implement these measures. In the Report’s view, universities lack the motivation and expertise to resolve research security issues, often prioritizing international partnerships and tuition revenue over security concerns.¹¹
• Importantly, the Report frames co-authorship as a potential compliance concern warranting further review, rather than a de facto violation; however, where a publication acknowledges NASA funding and includes co-authors affiliated with PRC institutions, it creates a “strong presumption” that the underlying research was conducted within the scope of the funded award.¹²

After setting forth over a dozen case studies—each drawn from the Select Committee’s bibliometric review and examining specific publications and institutions to illustrate potential compliance concerns—the Report concludes with several recommendations, of which the following are of particular relevance to research universities and other recipients of NASA grant funding:

• Congress should pass the Securing Innovation and Research from Adversaries (SIRA) Act, which Chairman John Moolenaar of the Select Committee and Senator Jim Banks introduced on May 14, 2026.¹³ The SIRA Act would prohibit any individual, while participating in or performing work under a federally funded research award, from conducting research with any entity, or any individual affiliated with an entity, on a United States Government restricted entity list.
• A joint task force between NASA Office of Inspector General (NASA OIG) and the Department of Justice should be established to investigate potential Wolf Amendment violations.
• Congress should direct NASA to prioritize and devote resources to its Research Security Program and the NASA OIG.
• NASA should review identified case study examples and provide public guidance, particularly on the “gray area scenarios” identified in the Report.
• NASA should pursue suspensions and debarments for universities identified as repeat offenders of the Wolf Amendment.
• NASA should prohibit collaboration with any entity on a U.S. government restricted entity list.
• NASA should require standardized inclusion of NASA award numbers in all NASA-supported publications.
• NASA should require program managers to undergo training to identify potential Wolf Amendment violations in publications submitted through Research Performance Progress Reports (RPPRs) to NASA.
• In publications for which NASA has provided any funding support, NASA should require that all specific author contributions be disclosed.
• The Executive Branch should establish a National Research Security, Integrity, and Compliance Center, which would consolidate all federal research security and due diligence efforts, establish uniform standards and policies and prohibitions, and provide cross-agency oversight and coordination.

Co-Authorship as a Compliance Indicator

A significant portion of the Report—including an Appendix entitled “Common Arguments Used to Oppose Strengthened Research Security Measures”—addresses the role of co-authorship in research security compliance, including Wolf Amendment compliance. The Report takes the position that co-authorship is not meaningfully distinguishable from collaboration, reasoning that authorship inherently reflects intellectual participation and creates pathways for knowledge transfer, even if direct interaction between co-authors has been limited. If a co-author did not meaningfully participate in the preparation of the publication, the Report argues, their inclusion misrepresents their contribution and constitutes a potential breach of academic integrity.

Notably, the Report includes recommendations aimed squarely at academic publishers—a sector that prior reports left largely unaddressed. Whereas earlier investigative reports focused their policy prescriptions on federal agencies, universities, and individual researchers, the Report now calls on publishers themselves to implement policies requiring verified and standardized author affiliation reporting, including mandatory disclosure of all institutional appointments, cross-checking to verify reported affiliations, and correction procedures for instances when inaccuracies are identified. This represents the first time the Select Committee has formally identified publishers as bearing independent responsibility within the research security and integrity framework.

This framing is significant because it signals a willingness to treat even informal or attenuated publication relationships with PRC-affiliated individuals or institutions as giving rise to compliance concerns. However, this equivalence does not clearly follow from existing NASA guidance, which has been inconsistent—a tension the Report itself acknowledges by simultaneously characterizing NASA’s guidance on co-authorship as “clear” while identifying numerous “gray areas” requiring further clarification from NASA.

Gaps in the Report’s Analytical Framework

Despite its length and detail, the Report fails to deal with some critical scenarios that universities and other research institutions often encounter related to the Wolf Amendment.

First, even in the cases the Report itself characterizes as “gray area” scenarios—such as instances in which researchers have held concurrent appointments as post-doctoral fellows at U.S. institutions while also maintaining affiliations with PRC institutions—the Report addresses only the fact of concurrent institutional affiliation and does not examine whether dual affiliations may only reflect a change in the researcher’s institutional affiliation over the course of the research and the eventual publication of the research. For example, if a post-doctoral fellow performs research in the United States while solely affiliated with a U.S. institution and begins a professorship at a PRC institution after the research is performed but before the manuscript is published, both affiliations may appear on the publication arguably without indicating any possible violation of the Wolf Amendment. By focusing exclusively on the face of the publication without interrogating the location of the underlying research work or affiliations while the individual was supported by NASA funding, the Report leaves this ambiguity unresolved and fails to account for its potential significance to any compliance determination.

This gap is compounded by a second, equally significant omission: the Report does not address the scenario in which a researcher receives NASA funding for only a portion of their activities—for example, 50 percent of their effort—while maintaining a completely separate collaboration with a PRC entity that is independently funded and completely unrelated to the NASA award.

Implications for Research Institutions

The enforcement landscape is shifting significantly: NASA and DOJ are applying broad interpretations of the Wolf Amendment and related certifications, even as congressional committees also have endorsed expansive Wolf Amendment interpretations and have pushed NASA and other law enforcement agencies to enforce that Amendment more aggressively.

The stakes are high. The report makes clear that false certifications, undisclosed affiliations, and failures to comply with statutory restrictions must not be treated as technical oversights—they are characterized as serious matters that may give rise to False Claims Act liability, including potential treble damages and civil penalties, as well as suspension and debarment from federal awards. Given the Select Committee’s call for a joint investigative task force and increased focus on foreign influence concerns generally, institutions in the near term should anticipate a substantial increase in enforcement activity.

The Report also reinforces the importance of robust institutional oversight of faculty collaborations, co-authorship practices, and compliance with NASA award terms and conditions. Research institutions receiving NASA funding should consider the following in light of the Report’s findings:

• Enhanced Due Diligence. The Report emphasizes the value of reviewing the scholarly record, including publication data and co-authorship patterns, to identify undisclosed affiliations and validate institutional disclosures. Institutions should consider conducting or enhancing bibliometric reviews of faculty publication histories (at least as far back as five to ten years), particularly when NASA funding has supported a faculty member’s research.
• Scrutiny of Collaborating Entities. Institutions should pay particular attention to the types of entities with which researchers collaborate, including whether they appear on the BIS Entity List, are part of China’s “Seven Sons of National Defense,” or are otherwise affiliated with PRC defense or intelligence activities.
• Authorship and Acknowledgment Guidance. Institutions should consider implementing more definitive authorship guidelines and guidance regarding acknowledgments that require students, post-doctoral fellows, and faculty to disclose accurately their individual author contributions, all their institutional affiliations, and funding support. Where past publications contain inaccurate authorship attributions or funding acknowledgments, the Report suggests institutions must ask researchers to seek corrections or retractions.
• Post-Award Monitoring. The Report criticizes the lack of systematic post-award monitoring of NASA grants and suggests that program managers should review publications submitted through RPPRs to identify potential compliance issues during the award period, rather than after funds have been expended. Impliedly, therefore, institutions should also review RPPRs and the publications included therein to try to identify any potential faculty non-compliance with the Wolf Amendment restrictions.

Ropes & Gray will continue to monitor developments in this area. Please contact the authors or your usual Ropes & Gray advisor with any questions or for advice on the topics discussed above.