Division of Research

NIH Requirements for Disclosure of Foreign Components

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NIH Requirements for Disclosure of Foreign Components

The National Institutes of Health (NIH) requires researchers to disclose any foreign components on research applications and awards.

Each agency provides its own definition of what constitutes a “foreign” or “international” component. The NIH's comprehensive definition of a foreign component includes:

  • Collaborations with investigators at a foreign site anticipated to result in co-authorship
  • Use of facilities or instrumentation at a foreign site
  • Receipt of financial support or resources from a foreign entity

Foreign travel for consultation is not considered a foreign component.

Disclosing Foreign Components

There are multiple ways in which foreign components can be appropriately disclosed to NIH, including:

  • Identifying a “foreign component” in an NIH grant application
  • Listing a “non-U.S. performance site”
  • Identifying foreign relationships and activities in a Biosketch
  • Checking “yes” to the question “Does this project involve activities outside of the United States or partnerships with international collaborators?” on the Cover Page Supplement Form

Related Resources

NIH Foreign Interference Policy

The NIH Foreign Interference policy outlines its position on international collaborations and foreign influence and provides additional guidance on the disclosure of other support, foreign relationships and activities and conflicts of interest.

FACTS Overview

The NIH employs the Foreign Award and Component Tracking System (FACTS) system to record all activities involving foreign countries.