NIH Reminds Researchers of Foreign Component Disclosure Requirements

By: CJ Neely
Thursday, June 11, 2026
NIH recently issued guidance reminding applicants and award recipients of long-standing requirements to disclose foreign components throughout the grant lifecycle, from application submission through annual progress reporting and publication of research findings (NOT-OD-26-084).

Under NIH policy, a foreign component extends beyond direct funding to foreign entities and may include any significant scientific element of an NIH-funded project conducted outside the United States or involving researchers employed by foreign organizations. Examples include participant recruitment, specimen or data collection, use of foreign laboratory facilities, and research activities performed by foreign collaborators.

The guidance underscores the importance of early disclosure and ongoing communication with NIH. Foreign components should be identified and justified during application submission, and new foreign activities that arise during the award period may require NIH review and approval.

NIH also reminded researchers to carefully review author affiliations and funding acknowledgments in publications. Inaccurate or incomplete information can create uncertainty about where the work was performed and whether foreign collaborations or activities were properly disclosed.

While emphasizing compliance and transparency, NIH reiterated that international collaborations remain an important part of the biomedical research enterprise. Researchers and institutions are encouraged to contact their NIH Program Officer if questions arise about whether an activity constitutes a foreign component or requires additional review. The notice reflects NIH's broader efforts to strengthen oversight of foreign collaborations while maintaining support for international scientific partnerships.