Reminder: NIH Definition of Foreign Components and Impacts of Co-Authorship

This notice reminds the extramural community of the requirement to notify the NIH when a project involves activities outside the United States or collaborations with international collaborators. While this is not a new requirement, the NIH recently released guidance outlining the requirement for proper acknowledgment of foreign components and related activities. As noted in the guidance document, “the central issue is not whether foreign collaboration occurs, but whether NIH is informed appropriately and approvals are obtained when required.” (It should be noted that in some cases, the Notice of Funding Opportunity may prohibit some or all foreign components.) As outlined in the NIH Grants Policy Statement, a foreign component is:

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. Activities that would meet this definition include, but are not limited to:

• the involvement of human subjects of animals at a foreign site
• extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or
• any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country

Examples of other grant-related activities that may be significant are:

• collaborations with investigators at a foreign site anticipated to result in co-authorship;
• use of facilities or instrumentation at a foreign site;
• foreign site recruitment;
• foreign specimen/data collection; or
• receipt of financial support or resources from a foreign entity.

Foreign travel for consultation is not considered a foreign component. A collaborator who moved abroad after the work was completed, or retention of a foreign vendor providing routine services, may not be considered foreign components.

Although the NIH has not expanded its definition of foreign components, it has increased its oversight of foreign collaborations and now takes a broad view of circumstances under which co-authorship constitutes a foreign component requiring pre-approval. The notice states, “Most instances of co-authorship represent a foreign component.” A recent article in Science magazine on May 20, 2026, highlights the dilemma being faced by researchers.

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.

The NIH requires grant applicants and award recipients to indicate whether the project involves activities outside of the United States or collaborations with international collaborators.
• If an applicant believes a foreign component is necessary, then the applicant must clearly explain the need at the time of submission in the Foreign Justification attachment accompanying the SF424 form.
• If a recipient believes a foreign component is necessary after the award is made, then they must first request prior review and approval from NIH to determine if the foreign component can be included as part of the project. See Section 8.1.2.10 of the NIH Grants Policy Statement.
• Recipients must annually report on their research progress, including with any approved foreign components. NIH staff review these materials to ensure NIH-supported activities remain consistent with approved award terms and policies.

BU Best Practices for Co-authorship

• Know your collaborators. Reach out to the Office of Research Security to conduct Restricted Party Screenings (RPS) on potential collaborators. While a RPS can only determine restricted status at the time of screening, it may help to prevent collaborations with entities or individuals already appearing on government lists.
• Be familiar with the BU guidelines for authorship.
• Be precise when acknowledging funding and affiliations.
  • Grants should only be cited if the grant directly supported the work described in the paper and the work described in the paper is within the scope of the grant.
  • Specify which authors are supported by which grants, especially if your co-authors are supported by foreign funding.
  • If you are supported by foreign funding, fully disclose your foreign funding in your Current and Pending (Other) Support.
  • If your foreign funding relates to a federal award, get prior approval from the grantor for any foreign component.
  • Increasingly, the situation arises where all of the work described in a paper is conducted at BU, but a student/postdoctoral scholar/visiting scholar involved in a material portion of the work returns to or accepts employment at a foreign university before publication is finalized. In that situation, if all of the work was conducted at BU, the student/postdoctoral scholar/visiting scholar should cite only their BU affiliation and not their current, foreign affiliation.

The full NIH notice can be found here.

Please also refer to Research Security’s website for more information on co-authorship considerations and best practices.

For grant-related questions on foreign components, please contact your SP Pre Award Officer; for other questions pertaining for foreign collaborations, please contact Research Security at ressec@bu.edu.