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, wbyerly1@uthsc.edu, with questions.