Some National Institutes of Health (NIH) entities are viewing foreign co-authorships as automatically constituting a foreign component. Investigators should be aware of this possibility and where possible proactively address potential foreign collaboration questions.
Investigators citing a foreign co-author on NIH funded work, for example in an RPPR submission, have been asked by NIH whether they obtained prior approval for the foreign component.
The NIH defines a foreign component as the performance of any significant element or segment of the project outside the United States either by the grantee or by a researcher employed by a foreign institution, whether or not grant funds are expended. NIH cites as one indicator of significance “collaborations with investigators at a foreign site anticipated to result in co-authorship.”
When preparing publication citations that include a collaborator at any non-U.S. institution, consider the nature of the work and collaboration. Note that this is not about the citizenship of the co-author but about where the NIH-funded work took place.
If all the work was done inside the United States, indicate that in the citation and include the name of the U.S. institution where that work was performed.
If work was done outside of the United States, and there is a pre-approved foreign component, no additions to the citation are required. If there is a foreign co-author working at an institution outside of the United States and there is no pre-approved foreign component, discuss the matter with your NIH program officer. If the program officer deems this may constitute an unapproved foreign component, contact your sponsored program officer about submitting a prior approval request.
If you receive questions from NIH after the submission of an RPPR regarding potential foreign co-authors, work with your sponsored program officer to provide a response and an appropriate action plan.