Published April 1, 2026, via Research News
Dear research community,
This is a reminder to the research community about the requirements for reporting foreign components on a National Institutes of Health (NIH) application and during the award. Under the NIH Grants Policy Statement, a foreign component is defined as “the performance of any significant scientific element or segment of a project outside of the United States… whether or not NIH grant funds are expended.” This includes work performed by a WashU researcher in a foreign location or by a researcher employed or paid by a foreign organization. For more details, see NOT-OD-19-114.
If a portion of the project will be conducted outside of the U.S., then a determination must be made as to whether the activities are considered significant. If both criteria are met, then there is a foreign component.
Examples of activities that may qualify as a foreign component include (but are not limited to):
- Foreign subawards
- Collaborations with investigators outside of the U.S. that are expected to lead to co-authorship (even if no funding is involved)
- Unpublished data sharing with investigators in foreign countries that may or may not lead to co-authorship
Please note that NIH is flagging Research Performance Progress Reports (RPPRs) where reported publications include authors located outside of the United States. Therefore, during the course of the award, you must obtain prior approval for a potential foreign component through your program officer or grants management specialist. You may be requested to provide a justification as to why the project is not viable without the collaboration.
Important clarification:
If someone worked on the project while they were in the United States but is now outside the country, this does not count as a foreign component. NIH may still inquire about this upon review of the publication.
This Foreign Component FAQ with Case Studies provide additional examples and guidance on when an activity should be reported as a foreign component.
Authorship, funding citations, and publication reporting should follow institutional and sponsor requirements. Authorship credit should always be consistent with WashU’s Authorship Policy.
Publications should always be included in the RPPR when they meet the criteria in 6.3 Section C – Products of the RPPR Instruction Guide.
If you receive a question from the NIH regarding a possible foreign collaboration or co-author, please contact Krystina Gross (kgross@wustl.edu) or researchgrants@wusm.wustl.edu. We are happy to help review the situation and work through the response with you.