Updated November 2026

NIH Foreign Component and Co-Authorship Guidance

Overview

NIH requires disclosure and, when applicable, prior approval for foreign components. A foreign component may be approved in the original NIH application and award. If one is added after an award is issued, NIH prior approval generally must be obtained before the foreign activity begins.

The key question is: Will a significant scientific element or segment of the NIH-supported project be performed outside the United States?

What is a foreign component?

NIH defines a foreign component as the performance of any significant scientific element or segment of a project outside the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.

A foreign component may exist even when:

No NIH funds are provided to the foreign individual or organization.
The foreign participant is unpaid.
There is no subaward or formal agreement.
The relationship is described as informal or remote.

Activities that may require NIH review or prior approval

Human subjects or vertebrate animal activities at a foreign site.
Experiments, data collection, surveying, sampling, or significant data analysis performed outside the United States.
Use of facilities, equipment, or instrumentation at a foreign site to perform a significant part of the project.
A foreign researcher contributing to research design, scientific decisions, interpretation of results, or other substantive intellectual work.
A collaboration with a foreign investigator expected to result in co-authorship or a joint publication.
A Purdue faculty member, employee, postdoctoral researcher, student, visiting scholar, consultant, or other project participant performing NIH-supported work while physically outside the United States.
A current collaborator moving to a foreign institution and continuing substantive work on the project.
Financial or in-kind resources from a foreign entity that support project activities performed outside the United States.

Activities that do not automatically constitute a foreign component

The following activities are not necessarily foreign components by themselves. Purdue and NIH will consider the actual work performed and the foreign party's scientific or intellectual role.

Situation	Generally not a foreign component by itself	Contact SPS when...
Co-authorship	A foreign co-author only edits or comments on a manuscript after significant scientific work was completed in the United States.	The person performs substantive scientific or intellectual work abroad. Anticipated co-authorship is a reason to review the facts.
Vendor or consultant	A provider performs a routine, defined service to Purdue specifications without scientific decision-making.	The provider helps design the research, develops methods, analyzes or interprets results, or otherwise functions as a collaborator.
Data or materials	A discrete, one-way transfer occurs without ongoing intellectual participation by the foreign provider.	The provider participates in research design, analysis, interpretation, or an ongoing scientific collaboration.
Foreign support	Financial or in-kind support is received, but no significant project work is performed abroad.	The support is tied to scientific work abroad. Other Support or RPPR disclosure may still be required even if no foreign component exists.
Earlier work	Foreign work was completed before the NIH project began.	New or continuing significant work occurs outside the United States during the NIH project period.
Researcher relocates	After moving abroad, the person only reviews or edits an existing manuscript based on U.S.-performed work.	The person continues experiments, analysis, data collection, research design, or other significant project work abroad.

Special considerations

Foreign co-authorship

Foreign co-authorship does not automatically establish a foreign component. However, co-authorship may indicate that the foreign researcher performed substantive intellectual or scientific work. Contact SPS when foreign co-authorship is anticipated so the relationship can be reviewed before the work begins or before new information is included in an RPPR.

Foreign vendors and service providers

A true fee-for-service arrangement generally is not a foreign component when the provider performs a routine, defined service and does not participate in research design, scientific decisions, method development, or interpretation of results. If the provider is expected to be a co-author or to contribute intellectually, the relationship may be a collaboration rather than a vendor arrangement.

One-way transfers of data or materials

A one-time transfer of data, specimens, or materials generally is not a foreign component when the foreign provider does not participate intellectually in the NIH-supported project. A Material Transfer Agreement or Data Use Agreement may document the transaction, but the actual activities determine whether a foreign component exists.

Foreign financial or in-kind support

Foreign financial or in-kind support does not, by itself, establish a foreign component. It may still require disclosure in Other Support, the RPPR, or other institutional disclosures. Examples include laboratory space, equipment, supplies, personnel, students, or donated analytical services.

What should Purdue investigators do?

Contact Sponsored Program Services Post Award as early as possible and before the foreign activity begins.
Provide enough information for Post Award to evaluate the proposed activity and determine whether NIH consultation or prior approval is needed.
Do not begin a new foreign component until NIH approval is received.
Do not wait until the RPPR or publication stage to report a potential foreign component.
Do not contact NIH independently about a potential or previously undisclosed foreign component unless coordinated through SPS.

Information to provide to SPS

NIH award number and PI name.
Name, institution, and country of each foreign participant or organization.
Description of the work and where it will physically occur.
The foreign party's role in research design, experiments, data collection, analysis, decisions, interpretation, and publication.
Whether co-authorship is anticipated.
Whether funds or in-kind resources will be provided or received.
Expected start and end dates.
Whether the activity was described in the application, award, or a prior NIH approval.
Relevant scope of work, agreement, correspondence, or supporting documentation.

NIH prior approval

If a foreign component was not included in the approved application or award, the activity generally must not begin until NIH prior approval is received. Other domestic project work may generally continue while NIH reviews the request. Purdue SPS will coordinate with the NIH Program Officer and Grants Management Specialist, as appropriate.

If delay could cause an irreversible scientific consequence, contact SPS immediately. Do not proceed with the foreign activity without institutional review and any required NIH approval.

Previously undisclosed activities

Contact SPS promptly if foreign project work may already have occurred without disclosure or approval. Examples include experiments or analysis performed abroad, an ongoing collaboration after a researcher moved to a foreign institution, or a publication involving a foreign co-author who performed significant scientific work outside the United States. SPS will coordinate the institutional review and any necessary corrective action.

Contact Purdue Sponsored Program Services Post Award before the activity begins if any part of an NIH-supported project may be performed outside the United States or may involve substantive scientific work by a person affiliated with a foreign organization.