A message from Brian Collier, Director of Research Security, Institutional Research Security Officer
On May 27, 2026, the National Institutes of Health (NIH) issued Notice NOT-OD-26-084. This notice seeks to remind researchers and institutions of the NIH policy regarding Foreign Components and clarify their stance on publications.
Key takeaways:
- All previous examples of foreign components that meet their definition of a foreign component remain in place
- NIH now considers most instances of international co-authors to represent a foreign component
- There may be some instances where the Notice of Funding Opportunity does NOT allow foreign components
- NIH-funded investigators should take care to accurately list their affiliations on publications to reflect where they performed the NIH-funded work rather than using their current affiliation if it is different from the performance site. For example, if a postdoc performed work at UNC but by the time of publication they are working at an international organization, their affiliation on the publication should be UNC.
Please remember that foreign components require prior approval – either at the time of proposal (as part of the application) or after award is made. In addition, please continue to list all collaborations – both domestic and international – on your Current and Pending (Other) support in the In-Kind section.