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[June 2, 2021] Foreign Components on NIH Applications and Award
NIH requires recipients to determine whether activities it supports include a foreign component, defined as: The existence of any “significant scientific element or segment of a project” outside of the United States, in other words:

1. performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or

2. performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.

To aide with what may be considered significant, click on the FAQ link below

If a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. If both criteria are met, then there is a foreign component. The addition of a foreign component to an ongoing NIH grant continues to require NIH prior approval, and should be requested as soon as it is considered, as outlined in the NIHGPS, Section 8.1.2 , Prior Approval Requirements.

If an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as other support.

For example, if a PD/PI of an NIH-funded grant has a collaborator outside of the U.S. who performs experiments in support of the PD/PI’s NIH-funded project, this would constitute a foreign component, regardless of whether the foreign collaborator receives funding from the PD/PI’s grant. Additional funding from a foreign source for the NIH-supported research of a PD/PI at a U.S. institution would not constitute a foreign component but would necessitate reporting as other support.

FAQs - Other Support and Foreign Components       

[March 18, 2021] Scrutiny by NIH Increasing on Collaborations with Foreign Entities and Personnel
There is increasing scrutiny of all collaborations which involve institutions and persons outside the U.S. In particular, NIH is reviewing publications and progress reports to identify new collaborations which were not originally included in an application or award.

Per NIH policy, including a foreign component requires prior approval.  Any known foreign collaborators should be declared in the proposal at the time the application is submitted.  If you have the opportunity to enter into a collaboration with a new foreign entity or person on an active NIH award, please work with OSPA to submit a prior approval request to NIH. The typical information needed includes:  
•    Name of collaborator(s), institute, and position (for each foreign site)
•    Collaborator’s mailing address, phone number, and email
•    Name of collaborating institution(s), city, and country
•    Nature of collaboration (i.e., Brief narrative that includes description of work performed at the foreign site and relevance to the project.  What is the collaborator’s role?  Will work result in publications? Why is it important to be done by the individual at a foreign site?)
•    Description of any chemical or biological material exchanged.
•    Will human subjects or vertebrate animals be involved with the collaborator?
•    Description of how Federal funds used regarding these collaborations.
•    Will the work be viable without the collaboration?

It is important to note that some requests must be reviewed by the U.S. State Department, which may increase review time.

For more information, please see this NIH Notice or contact your SPO. [Faculty, Postdocs and Resadmin 3/18/2021] 

[Febuary 11, 2021] Are hyperlinks allowed in NIH applications? Due to concerns regarding reviewer confidentiality, circumventing page limits, review consistency, and malware, the use of hypertext (e.g. hyperlinks and URLs) in NIH applications is restricted (details in NIH Notice).  Hyperlinks are only allowed when specifically noted in the Funding Opportunity Announcement (FOA). The use of hyperlinks is usually limited to citing relevant publications in biosketches and publication lists. A reminder that if you include the optional link to a full list of your published work, the URL is .gov (i.e., a site such as My Bibliography). Applications that do not follow these instructions, and include unallowable hyperlinks, may be withdrawn from review and funding consideration. More>> [Faculty, Postdocs and Resadmin 2/11/2021]  

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