Acknowledging Foreign Components throughout NIH Application and Award Processes

NIH supports international scientific collaboration when conducted transparently and in accordance with NIH requirements. The key expectation is timely and accurate disclosure of foreign components and related activities. Here we are sharing reminders about how to properly acknowledge foreign components in NIH grant applications, progress reports, and manuscripts resulting from NIH awards (see the recently released NIH Guide Notice NOT-OD-26-084 for more).

What is a foreign component?

NIH defines “foreign component” broadly as 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 (see also this section of the NIH Grants Policy Statement). It may or may not involve funds to a foreign entity.

Here are some examples of what may be and what may not be foreign components:

What is required related to foreign components? 

NIH requires applicants to indicate whether the project involves activities outside of the United States or partnerships with international collaborators. This has been a requirement since 2006 and is specified in the SF424 application instructions, which all applicants must follow when submitting a grant application to NIH. In April 2025, we also posted a reminder to the extramural research community about these long-standing application requirements for projects involving activities outside of the United States or partnerships with international collaborators (NOT-OD-25-098).

• If an applicant believes a foreign component is necessary, then the applicant must clearly explain the need at the time of submission in the Foreign Justification attachment accompanying the SF424 form.
• If a recipient believes a foreign component is necessary after the award is made, then they must first request prior approval from NIH (see this section of the NIH Grants Policy Statement). NIH will review the request, engaging with the recipient as appropriate, to determine if the foreign component can be included as part of the project.
• Recipients must annually report on their research progress, including with any approved foreign components. NIH staff review these materials to ensure NIH-supported activities remain consistent with approved award terms and policies.
• Recipient institutions are responsible for ensuring complete and accurate disclosure, and should have processes to review foreign components before submission and during award management.

Sometimes it’s not so clear… 

We understand that sometimes the situation is complicated. For instance:

• The principal investigator only learns that a domestic collaborator was also working with a foreign collaborator when first seeing a draft of a manuscript. It is important to review affiliations in publications as they can reveal undisclosed foreign collaborations/components.
• A former postdoc leaves the lab to become an assistant professor in another country. A publication describing their postdoctoral work lists their affiliation as their new institution instead of that of their postdoctoral lab. In this situation, their affiliation should have been listed as the lab where they did the work with a note clarifying what their current address is. Acknowledgments and affiliations should accurately reflect where work was performed.
• Publications and progress reports should accurately acknowledge the NIH award that supported the work, where it was performed, and affiliations associated with the research activities. If more than one grant supported the work, it is important to delineate which grants support which parts. Inaccurate acknowledgments, affiliations, or citations may create confusion regarding whether NIH-supported activities involved undisclosed foreign components. Learn more about properly acknowledging NIH support in these archived Nexus articles from October 2023 and April 2021.

What should you do?

The central issue is not whether foreign collaboration occurs, but whether NIH is informed appropriately and approvals are obtained when required. 

When instances like these happen, the important thing to remember is to report it to NIH as soon as you learn about it. We will work with recipients to assess the situation and determine whether corrective action or prior approval is needed. Paying attention to appropriate citation of NIH awards and involvement of foreign components is a part of how we ensure proper stewardship and accountability of taxpayer support and assure that the results of NIH funding are properly reported.

There are cases where grant funds from certain programs cannot be used to support the work of foreign collaborators. Check the Notice of Funding Opportunity for the grant you are applying for to see if there are any restrictions of this kind.

We appreciate the research community’s continued partnership, which is pivotal for strengthening our combined oversight of foreign collaborations and research investments. 

Additional Resource:

NIH Extramural Nexus: When Will NIH Contact You Regarding a Missing Attachment?