By MinessaForeign collaborations in research are becoming more frequent and bring unique challenges, especially given the current focus on foreign involvement in federally funded projects. As a research administrator, it’s essential to understand the rules and policies governing these collaborations to guide your principal investigators (PIs) and ensure compliance. Below are some key points to consider—but to explore these topics in greater detail, watch the video I created, which serves as a starting point for this complex conversation.
What Is a Foreign Component?
A “foreign component,” as defined by the NIH, refers to the performance of any significant scientific element or segment of a project outside the U.S., whether or not NIH grant funds are spent. Examples include:
- Collaborations with foreign investigators resulting in co-authorship.
- Use of foreign facilities or equipment.
- Extensive travel to foreign countries for data collection or similar activities.
For an official definition, refer to the NIH Grants Policy Statement and the NIH Guide Memo on Foreign Components.
Reporting Foreign Components
If your PI is considering a foreign collaboration, it must be disclosed as part of the grant proposal process. Disclosure occurs in several sections, including:
- Biosketch: Highlight joint publications or appointments with foreign institutions. See the NIH Biosketch Guidelines for more details.
- Budget Justification: Include foreign subawards, consultants, or collaborations. Review the NIH’s SF424 Application Guide for instructions.
- Foreign Justification: Provide a detailed rationale for conducting research outside the U.S.
Ensure you review the NIH Decision Matrix on Foreign Interference for compliance guidance.
Foreign Travel and “Other Support”
Foreign travel conducted as part of NIH-funded projects may also need to be reported if it involves significant data collection or other activities tied to the project. For travel unrelated to the project but funded by a foreign entity, disclosure is required under “Other Support.”
Visit the NIH Other Support Page for more details on what constitutes “Other Support” and how to disclose it.
Compliance with Organizational and Federal Policies
Foreign collaborations often involve additional considerations beyond NIH guidelines, including:
- Institutional Policies: Your organization’s compliance office or legal team should be consulted to align foreign collaborations with internal policies.
- Countries of Concern: Special rules may apply when collaborating with individuals or entities from specific nations. See the NIH’s Countries of Concern Guidelines for details.
For broader compliance concerns, review the NIH’s Protecting U.S. Biomedical Intellectual Innovation page.
Closing Thoughts
Foreign collaborations add complexity to research administration, requiring diligence and proactive planning. If your PI is working with international collaborators, start by asking about their relationships, planned activities, and compliance history. Use this understanding to navigate NIH requirements and your organization’s policies effectively.
For more insights, real-world examples, and practical tips, watch my video on foreign collaborations and compliance. It’s designed to spark questions and discussions with your team, compliance office, and legal counsel—because managing foreign collaborations is a team effort. Let me know your thoughts in the comments!
Resources for Reference:
- NIH Grants Policy Statement
- NIH Guide Memo on Foreign Components
- NIH Decision Matrix on Foreign Interference
- NIH Other Support Page
- Countries of Concern Guidelines
- Protecting U.S. Biomedical Intellectual Innovation