Foreign components are defined as a significant scientific element or segment of a project outside of the United States. Significant work performed by a researcher in a foreign location qualifies as a foreign component, whether or not NIH funds are expended.
All foreign components must receive NIH prior approval. If a PI determines that a portion of the project will be conducted outside of the U.S., determine if it is considered significant and secure NIH prior approval via OSP.
What do I do if the work is considered significant?
If the work is considered significant :
- Draft a prior-approval request for the activity including the location on department letterhead
- Address the request to the NIH GMS
- Forward the request to OSP
- OSP will submit the formal prior approval request to NIH
Failure to achieve explicit NIH prior approval for foreign components may result in return of funds to NIH, termination of the award, or other measures as determined by NIH.
Other federal sponsors have similar requirements. Please check your award before proceeding with a foreign component.
- NIH: NOT-OD-09-114 Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components
- NIH Definition of Terms: Foreign Component
- NIH Other Support FAQ: What are some examples of a “significant element of a project” when making determinations regarding a foreign component?
- UW FAQ: Is it considered prior approval when I report upcoming work in a foreign location within my RPPR and receive continuation funding for the next year?