RESEARCHERS: Update on Foreign Components and Associated Reporting Requirements

NIH Reminder: Foreign Component Definition and Reporting Requirements

NIH has issued a reminder clarifying the definition of foreign components and associated reporting obligations. See NOT-OD-26-084 for full details - notably, NIH now states that most instances of co-authorship constitute a foreign component.

What counts as a foreign component? Any significant scientific element or segment of a project performed outside the U.S., regardless of whether grant funds are used, including:

• Human subjects or animal research at a foreign site
• Extensive foreign travel for data collection, surveying, or sampling
• Any activity that may impact U.S. foreign policy through involvement in a foreign country's affairs or environment

Reporting requirements apply at multiple stages:

• Applications: Disclose in Other Support and include a Foreign Justification attachment
• Active awards: Request prior approval before adding a foreign component
• Annually: Report in Research Performance Progress Reports (RPPRs)

For more information, visit NIH's Requirements for Disclosure of Other Support, Foreign Components and Conflicts of Interest. Contact Dr. Wesley Byerly, [email protected], with questions.