Foreign component disclosure

In the NIH grants framework, a foreign component is the performance of any significant scientific element or segment of an NIH-funded project outside the United States — by the recipient institution itself or by a researcher employed by a foreign organisation — whether or not any NIH grant funds are actually spent on it. The trigger is where part of the funded work happens, not who is being paid or what resources a researcher personally holds.

What counts, and what does not

NIH and its awardee institutions treat the following as foreign components: a collaboration with a foreign-site investigator expected to produce co-authorship; use of a facility or piece of instrumentation located abroad; receipt of financial support or resources from a foreign entity for the project; involvement of human subjects or animals located abroad; extensive foreign travel by project staff for data collection, surveying, or sampling; and any project activity that could affect US foreign policy through involvement in a foreign country’s affairs or environment. Foreign travel undertaken purely for consultation — attending a conference, giving a talk — is explicitly not, by itself, a foreign component. Purchasing reagents or equipment from a foreign vendor, with no work performed abroad, is likewise not a foreign component on its own; see how listing a foreign co-author or affiliation can trigger foreign-component disclosure for the borderline cases that most often catch investigators by surprise.

Disclosure is required at application, in the project description and budget justification, and again whenever a foreign component is added or materially changes during the project — this is a prior-approval-type requirement tied to project scope, not a standing biographical filing. That is the key distinction from Current and Pending Support, which discloses everything an individual investigator holds regardless of where any of it is performed, and from in-kind contribution disclosure, which covers non-monetary resources received rather than project work physically performed overseas — a foreign component can exist with no in-kind contribution involved, and vice versa. A related but separate NIH mechanism, foreign subaward requirements, applies when the foreign work is carried out through a formal subrecipient agreement. NIH has repeatedly reinforced this definition — most recently reissuing it in 2026 via Guide Notice NOT-OD-26-084 — after failures to disclose foreign components were identified as a recurring finding in research-integrity reviews following NIH’s 2018–2019 foreign-influence inquiry.