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The NASA Proposer's Guide (February 2023) includes similar language to the Wolf Amendment in a footnote of section 2.16, Current and Pending Support. Per the footnote, 'China or Chinese-owned Company' means the People's Republic of China (PRC), any company owned by the PRC, or any company incorporated under the laws of the PRC. Chinese universities and other similar institutions are considered to be incorporated under the laws of the PRC and, therefore, the funding restrictions apply to grants and cooperative agreements that include bilateral participation, collaboration, or coordination with Chinese universities.

The 'Wolf Amendment' (2011) prohibits participation, collaboration, or coordination bilaterally with China or any Chinese-owned company on any NASA project at the prime or subrecipient level. NASA clarified in a September 2022 presentation that the agency defines a 'Chinese-owned company' as any company owned by China, or any company incorporated under the laws of China, and that Chinese universities and similar institutions are considered to be incorporated under the laws of China and therefore the funding restrictions apply.