NIH has specific requirements regarding the reporting of foreign components, see below for details. However, many federal funding agencies may require some type of reporting for foreign collaborations associated with the grant. The best practice is to review the specific agency requirements and, when in doubt, contact your program officer.
NIH
Under NIH’s Grants Policy Statement, a foreign component is defined as “any significant scientific element or segment of a project outside of the United States” whether or not NIH grant funds are expended, either by “a researcher or recipient in a foreign location or by a researcher in a foreign location employed or paid by a foreign organization.” Refer to NIH issued guidance: NOT-OD-19-114 for the complete details.
When a segment of the research is performed outside of the U.S., the following activities would constitute a foreign collaboration and disclosed as a foreign component:
- Research involving human subjects or animals;
- Extensive travel for the purpose of data collection, surveying, sampling, and similar activities (excluding foreign travel for consulting);
- Collaborations with investigators anticipated to result in co-authorship;
- Use of facilities or instrumentation; or
- Receipt of financial support or resources from a foreign entity.
Examples of ways to disclose a foreign component in a NIH funding application
- Identifying a foreign component in an NIH grant application on the R&R Other Project Information Form (G.220):
- Check “Yes” to Question 6, “Does this project involve activities outside of the United States or partnerships with international collaborators?”
- Upload a “foreign justification” document in Field 12, Other Attachments. This attachment should describe the resources or characteristics of the foreign research component (e.g., human subjects, equipment, research techniques, etc.) including reasons why the use of foreign facilities or other aspects of the project are appropriate for an international setting.
- Listing a “non-U.S. performance site”
- Reporting a NIH Annual Research Performance Progress Report (RPPR)
- Special Reporting Requirements – Section G
- G.9 Foreign component. Provide the name, country, and description of each foreign component.
Questions
Contact the Office of Sponsored Research Services at researchgrants@wusm.wustl.edu or 314.747.4134.