Per 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. If any portion of a project is conducted outside the U.S. and the activities are deemed significant, it must be considered a foreign component. As noted in NOT-OD-19-114, adding a foreign component to an ongoing NIH award requires prior NIH approval.  

We have received reports that NIH is increasingly flagging Research Performance Progress Reports (RPPRs) that include publications with co-authors located outside the United States. If a foreign component was not disclosed in the original application but later results in such publications, prior approval must be obtained. Failure to do so may result in NIH requesting removal of the publication from the RPPR or requiring additional justification.  

Prior approvals or questions regarding this can be submitted to the OGC PreAward at xenia@ucdenver.edu. 

For more information from Post-Award Administration, click here.