Disclose foreign components to be in compliance

The National Institutes of Health (NIH) requires prior approval for any foreign component, defined as “The performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.”

This includes but is not limited to:

• extensive foreign travel by project staff for the purpose of data collection, surveying, sampling and similar activities;
• collaborations with investigators located at a foreign site anticipated to result in co-authorship;
• use of facilities or instrumentation at a foreign site; or
• receipt of financial support or resources from a foreign entity. 

Foreign travel for consultation is not considered a foreign component.

Researchers are required to disclose a foreign component completely, accurately and to the best of the investigator’s knowledge. Contact your sponsored program officer to obtain prior approval from the NIH for any foreign component.