Background
NIH has recently received questions regarding whether there has been a change in the definition of a foreign component, and whether a foreign co-author on a publication that cites an NIH grant award automatically results in a foreign component.
Purpose
This notice reminds the extramural community of NIH's longstanding definition of foreign components. While NIH has increased its oversight of foreign collaborations, they have not expanded the definition of foreign components. As outlined in the NIH Grants Policy Statement, a foreign component is:
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. Activities that would meet this definition include, but are not limited to
- the involvement of human subjects or animals at a foreign site,
- extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or
- any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country.
Examples of other grant-related activities that may be significant are:
- collaborations with investigators 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.
Most instances of co-authorship represent a foreign component. The NIH recognizes, however, that certain contributions are so minor that they do not constitute an actual collaboration. For example, the provision of a single reagent might not be a collaboration but could result in co-authorship. In addition, occasionally co-authorship arises through indirect association, such as when an NIH-funded researcher and a foreign researcher both independently work with the same domestic collaborator but only learn of this fact when a manuscript is prepared describing the work. In all cases, NIH recipients should report foreign co-authorship to the funding Institute or Center as soon as they are aware of it to determine what steps, if any, need to be taken.
Recipients must pay close attention to the Notice of Funding Opportunity (NOFO), which outlines whether foreign components are permitted. For awards that are issued from NOFOs that do not allow foreign components, publications and other research projects generally should not include foreign co-authors or collaborators. See the Full Notice for additional information.
Full Notice
National Institutes of Health
NOT-OD-26-084
May 27, 2026
NIH Validation Service in Cayuse
A reminder that Cayuse includes a specialized validation feature called NIH Validation. This option sends your proposal data directly to the NIH validation system, where it is checked for errors. Any errors or warnings identified are then displayed for your review, including issues related to Common Forms.
To utilize this feature, simply click on the Validate Proposal with NIH box on the Electronic Submission page:
Prior to routing an NIH application to DSP in Cayuse, users are encouraged to validate the proposal using both the NIH Validation and the traditional Validate Proposal functions. If you have questions, please contact nih@uiowa.edu.
