Important:
If you establish a new foreign collaboration during an active NIH award, including new foreign co-authorship or publications that may constitute a foreign component, do not wait until your RPPR is due. Contact OSR immediately so we can determine whether NIH prior approval is required before RPPR submission.
NOT-OD-26-084 Most Foreign Co-Authorship is a Foreign Component.
- NIH emphasizes that most foreign co-authorship arrangements represent a foreign component.
- A foreign component is the performance of any significant scientific element or segment of an NIH-funded project outside the United States, whether or not NIH funds are spent abroad.
Here are some examples of what may be and what may not be foreign components:
| May Be a Foreign Component | May Not Be a Foreign Component |
| Foreign site recruitment | Foreign travel for consultation |
| Foreign specimen/data collection | A collaborator who moved overseas after the work was completed |
| Use of foreign lab facilities | Foreign vendors providing routine services |
| Work performed by a foreign collaborator | Foreign co-author providing minor editorial feedback |
| Co-authorship |
Disclosure Requirements
- Applicants must identify activities conducted outside the U.S. and international collaborations in their application.
- If a foreign component is proposed, investigators must provide a Foreign Justification explaining why the activity is necessary.
- If a foreign component arises after an award is made, prior NIH approval is generally required before the activity begins.
- Review the Notice of Funding Opportunity (NOFO) to determine whether international collaborations or foreign activities are permitted.
Publications and Progress Reports
- Accurately acknowledge NIH funding in publications and reports.
- Cite only grants that directly supported the work described.
- Clearly identify which grant supported which portion of the research when multiple awards contributed.
- Approved foreign components must be reported in annual progress reports.
- Ensure author affiliations reflect where the NIH-funded work was performed, rather than solely listing a current institution.
Inaccurate grant citations, affiliations, or acknowledgments may create an undisclosed foreign component and can trigger NIH compliance inquiries.
7/15/2026 - PI Certification in eProposal for Foreign Collaborations
UCSF is introducing additional policies, enhanced communication, and refined procedures to further ensure compliance with NIH foreign collaboration reporting requirements.
The following attestation from the PI at the time of submission.
I understand NIH policies and requirements for foreign collaboration, and that I have a professional and ethical responsibility to disclose any foreign collaborations.
I understand that omitting information or failing to disclose foreign collaboration is a violation of NIH policies and could lead to loss of grant funding.
I understand that my signature on the Other Support form affirms that I have reviewed the information contained therein and all information is current, accurate, and complete.
I understand that submitting misinformation to NIH puts me at risk of violating UCSF Code of Conduct requirements, puts UCSF’s reputation at risk, and could lead to NIH imposing increased administrative requirements or withholding funds.
NIH Slide Presentation on Foreign Co Authorship/Foreign Components
The Council on Governmental Relations (COGR) has posted presentation slides from a discussion on June 10th 2026 with the NIH Office of Policy for Extramural Research Administration (OPERA) on when foreign co-authorship constitutes a foreign component requiring prior NIH approval.
The presentation includes 8 case studies that clarify NIH's expectations and may be helpful for institutions and investigators managing NIH-funded research. Researchers and research administrators are encouraged to review the Foreign Component Discussion with NIH materials available on the COGR website.
Originally Posted 6/8/2026, updated 7/15/2026