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.
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