NIH Foreign Collaborator FAQ
The School of Medicine: RAISE, in collaboration with the Office of Sponsored Programs and the Research Security Office have developed this FAQ. Contact Sponsored Programs for grant-specific guidance.
General Questions
NIH defines a foreign component as the performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended. Examples of activities that may meet this definition include collaborations with investigators at a foreign site anticipated to result in co-authorship, use of facilities or instrumentation at a foreign site, and receipt of financial support or resources from a foreign entity. Foreign travel for consultation alone does not constitute a foreign component.
No. These requirements apply to NIH-funded projects, meaning projects where NIH is the funding source or where the publication is being attributed to an NIH award. The key threshold question is whether the research project, or the portion of the work being described in the publication, is NIH-supported. If the manuscript cites an NIH award, the PI/department should consider whether any foreign-affiliated co-authorship or foreign involvement should be reviewed by OSP.
No. A researcher having both a U.S. affiliation and a foreign affiliation does not automatically create a foreign component.
The key consideration is where the scientific work was performed and whether activities conducted outside the United States constitute a significant scientific element or segment of an NIH-supported project. The affiliation listed on a publication may be relevant, but NIH’s analysis focuses primarily on the activities performed and the resources involved.
When uncertainty exists regarding a dual-affiliated author’s contribution, investigators should consult OSP.
Generally, yes. Most instances of co-authorship represent a foreign component. The NIH recognizes, however, that certain contributions are so minor that they do not constitute an actual collaboration. For example, the provision of a single reagent might not be a collaboration but could result in co-authorship. In addition, occasionally co-authorship arises through indirect association, such as when an NIH-funded researcher and a foreign researcher both independently work with the same domestic collaborator but only learn of this fact when a manuscript is prepared describing the work.
Because foreign co-authorship may be an indicator of a foreign component, investigators should submit the PAR Form and PI letter to OSP whenever a publication arising from NIH-supported work includes foreign-affiliated collaborators and there is uncertainty regarding reporting obligations.
Potentially, yes.
Federal agencies increasingly review foreign funding relationships as part of research security and disclosure requirements. Foreign awards, subawards, and other sponsored research relationships should be disclosed in accordance with applicable federal sponsor requirements, including Current and Pending Support or Other Support reporting requirements when applicable.
Particular attention may be given to funding originating from countries of concern or entities that have been identified by the federal government as presenting elevated research security risks.
Investigators should work with the Research Security Office to ensure appropriate disclosure and documentation of foreign funded activities.
Scenario 1
Project not funded by NIH, but manuscript acknowledges an NIH core facility grant.
Generally, no. The NCI center core support grant supports shared infrastructure of the core facility, not necessarily the specific research project described in the manuscript. Acknowledging use of a UNC core facility that is supported in part by an NCI grant does not, by itself, make the project NIH-funded for purposes of the foreign component requirement. However, if any NIH award directly supported the research described in the manuscript, or if the manuscript will cite an NIH award beyond the required core acknowledgment, the PI/department should contact OSP for review.
No. Do not remove an accurate core facility acknowledgment solely to avoid confusion. The acknowledgment credits the infrastructure that made the work possible and may be required by the core facility. This is different from attributing the scientific project itself to an NIH award that did not support the work.
Yes. If you hold other active NIH awards, consider whether your foreign collaborator’s contributions to this manuscript could be construed as work performed in support of one of those grants. If the science in this paper is related to an active NIH-funded project, that would be a separate analysis, and you should contact OSP. If the work is genuinely unrelated to any active NIH awards and the publication is not otherwise being attributed to NIH support, the NIH foreign component requirement generally would not apply.
Use of materials generated during a completed NIH-funded project does not automatically make a new study NIH-supported.
Investigators should consider whether:
- the new work falls within the scope of the original NIH project;
- the NIH award is being cited in the manuscript;
- the publication reports results that were part of the funded aims; or
- the work was included in NIH progress reports associated with the award.
If the new research falls outside the scope of the completed NIH project and is supported by other funding sources, NIH foreign component requirements may not apply. When uncertainty exists, consult OSP before publication.
Not necessarily.
The fact that an NIH award originally generated samples, specimens, or materials does not automatically mean that all future studies using those materials should be attributed to the award. Investigators should evaluate whether the work being published was actually supported by the NIH-funded project and falls within the scope of the award.
If the new study is outside the original project scope and is supported by other funding sources, citation of the NIH award may not be appropriate. Investigators should consult OSP if they are uncertain about attribution requirements.
Yes. A foreign collaborator may generally acknowledge funding that supported their contribution to the research. The existence of a foreign funding source does not automatically create a compliance concern when the collaboration has been appropriately reviewed and documented.
However, investigators should be aware that publications acknowledging foreign funding – particularly from countries of concern – may receive additional scrutiny during future federal research security reviews. The CHIPS and Science Act (2022) defines countries of concern to be China, Iran, North Korea, and Russia. In any case, funding agencies may ask follow–up questions regarding the nature of the collaboration, whether any funds were provided to UNC investigators, and whether resources were exchanged between institutions. Investigators should maintain documentation that clearly describes the relationship and the respective contributions of each party.
If the foreign funding materially supported work included in the publication, standard scholarly practice is to acknowledge that support accurately in the manuscript.
Generally, no. NIH prior approval requirements apply to NIH–funded projects. If the research described in the manuscript was not supported by NIH funding and the publication is not being attributed to an NIH award, NIH approval is typically not required before submission or publication.
Investigators should nevertheless confirm that no active NIH award supported the work being reported and that the publication will not cite NIH funding other than required facility or infrastructure acknowledgments. When uncertainty exists, contact OSP for guidance.
Scenario 2
Former postdoc now at a foreign institution is a co-author
Typically, no, but consult with your research administrator for clarification.
If the scholar’s role concluded while at UNC, list UNC as scholar’s affiliation for that work and clarify their new, foreign institution as a current or present address. If additional experiments were conducted after the researcher joined the foreign institution, including a note explaining where the work was performed may provide the greatest transparency.
However, correct affiliation alone may not fully resolve the issue. NIH’s current guidance says recipients should report foreign co-authorship to the funding Institute or Center as soon as they are aware of it so NIH can determine what steps, if any, are needed. PIs should therefore flag these situations to OSP before submission when possible, especially when the publication cites an NIH award.
Generally, yes. If the foreign component was disclosed to NIH in the original application, subsequently reported through appropriate NIH channels (such as an RPPR), and the award was issued or continued without modification, that is generally considered NIH approval of the foreign component.
In those circumstances, investigators from the approved foreign site may generally be included as co-authors on publications arising from work associated with the approved foreign component. Investigators should continue to ensure that publications accurately reflect the contributions, affiliations, and funding sources associated with the work.
If there is uncertainty regarding whether the publication falls within the scope of the approved foreign component, contact OSP for guidance before submission.
Co-authorship should be determined using normal scholarly authorship standards. If individuals made contributions that justify authorship under accepted disciplinary and journal guidelines, they may be included as co-authors regardless of institutional affiliation.
If the collaboration cites NIH funding, then investigators must work with OSP to receive prior approval from NIH for the foreign component.
Further, investigators should recognize that adding additional authors from foreign institutions increases the scope of the international collaboration and may receive additional review in the context of research security assessments, particularly when institutions from countries of concern are involved. As such, investigators should maintain records describing each author’s specific contributions to the work and be prepared to provide that information if requested.
Contact OSP as soon as possible. NIH reviews affiliations listed in publications cited in progress reports and may flag foreign-affiliated co-authors for follow – up. The PI/department should not assume the issue is resolved by the affiliation alone or by correcting the publication without OSP input. OSP can advise whether any NIH communication, correction, or documentation is needed.
Generally, no. NIH does not currently require advance review of manuscripts solely because they include foreign collaborators or foreign-affiliated co-authors. Prior approval requirements are driven by NIH policy and the specific terms and conditions of an award, not by publication authorship alone.
However, NIH has increased its focus on foreign components and international collaborations. If a publication arising from NIH-supported work includes foreign collaborators or raises questions about whether a foreign component exists, investigators are encouraged to consult OSP before submission. In some situations, OSP may recommend contacting the NIH Program Officer for guidance.
Not necessarily, but it may be advisable in situations where there is uncertainty about whether foreign activities, resources, facilities, analysis, or co-authorship could constitute a foreign component under NIH policy.
While NIH does not generally require routine pre-publication approval, investigators may benefit from proactively communicating with their Program Officer when a foreign collaboration raises novel or complex questions. Early communication can help clarify whether NIH expects additional documentation, reporting, or prior approval.
Yes. Ongoing collaborations that provide resources, data, facilities, materials, scientific effort, or other in-kind contributions related to NIH-supported activities require disclosure in NIH Other Support documentation.
Scenario 3
Foreign collaborator reviewing data or discussing results remotely
It depends on the nature and extent of the foreign collaborator’s contribution. NIH’s formal definition focuses on the performance of a significant scientific element or segment of the project outside the United States. Activities such as substantive data analysis, interpretation of results, image review that contributes to the scientific conclusions, or other intellectual/scientific contributions may require OSP review, particularly if they result in co-authorship on an NIH-supported publication.
Minor editorial comments or limited consultation may not rise to the level of a foreign component, but PIs should not make that determination independently when the publication cites NIH support. Contact OSP before submission whenever possible.
The key issue is usually not the personal computer itself, but the nature of the scientific work performed outside the United States. NIH’s examples include use of facilities or instrumentation at a foreign site, but the policy also focuses more broadly on whether a significant scientific element or segment of the NIH-supported project was performed outside the U.S. If the foreign collaborator’s review of images or data contributed substantively to the analysis, interpretation, conclusions, or authorship of an NIH-supported publication, the PI/department should contact OSP for review.
As an additional reminder, accessing or sending data and technologies abroad can constitute an export under Export Controls. While non-tangible University research products intended for publication without restrictions are typically excluded from export controls, you should consult with the Export Compliance Office if you have concerns, or when critical or emerging technologies are involved.
Contact OSP before the paper is submitted whenever possible. If the paper has already been submitted or published and is cited on an NIH-funded grant, contact OSP as soon as possible. OSP will determine the appropriate institutional response, which may include documentation, communication with the NIH funding Institute/Center, a prior approval request if applicable, or other corrective action.
The answer depends on the relationship between the analysis and the original NIH-funded project.
Factors that may be relevant include:
- whether the publication was cited in a final progress report;
- whether the manuscript cites NIH funding from the completed award;
- whether the analysis falls within the original scope of the funded project; and
- whether the foreign collaborator’s contribution constitutes a significant scientific contribution.
Because NIH’s interpretation may vary based on the facts of a particular case, investigators should consult OSP and, when appropriate, the NIH Program Officer before publication.
Yes. P30 grants often support shared infrastructure, cores, pilot projects, and publications involving a wider range of investigators and collaborators than a single R – series grant. Because of that, P30 PIs and publication coordinators should build a review step into the publication process before submission to identify:
- whether the publication cites the P30 or another NIH award;
- whether any author has a foreign institutional affiliation or current address; and
- whether any scientific work, analysis, resources, or facilities were provided from outside the United States.
If any of these apply, contact OSP before submission when possible.
Still have questions?
Contact OSP directly for grant – specific guidance.
Contact the Research Security Office for compliance support.
RAISE can help facilitate that connection or answer general process questions.
Sources:
NIH Official Guidance
- NOT – OD – 26 – 084: Reminder – Definition of Foreign Components (May 2026)
- NOT – OD – 19 – 114: Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (July 2019)
- NIH Extramural Nexus: Acknowledging Foreign Components throughout NIH Application and Award Processes (June 2026)
- NIH Grants Policy Statement 8.1.2 – Prior Approval Requirements
- NIH: Communicating and Acknowledging Federal Funding