Applications Involving a Foreign Component

The NIH has tightened its requirements for applications that involve a foreign component.

Applications missing the required Foreign Justification attachment are subject to administrative withdrawal by the NIH prior to review.

Per page 63 of the SF424 Application Guide, applications submitted by foreign institutions or by domestic (U.S.) institutions with a foreign component, as defined in the NIH Grants Policy Statement, must include a “Foreign Justification” statement as part of the application package.

  • This requirement is applicable regardless of eligibility requirements statement in the Notice of Funding Opportunity.
  • If answering YES to question #6 on the R & R Other Project Information form, the justification must be provided.
    • Does this project involve activities outside of the United States or partnerships with international collaborators?

The foreign justification should be provided as a separate attachment in the “12. Other Attachments” section in the R & R Other Project Information Form and named “Foreign Justification.”

  • Describe special resources or characteristics of the research project (e.g., human subjects, animals, disease, equipment, and techniques), including the reasons why the facilities or other aspects of the proposed project are more appropriate than a domestic setting. In the body of the text, begin the section a heading indicating “Foreign Justification” and name the file “Foreign Justification.”

 

  • 6.a. If YES, identify countries: Enter the countries with which international cooperative activities are planned. You may use abbreviation. Your entry is limited to 55 characters.
  • 6.b. Optional Explanation: This field is optional. Enter an explanation for involvement with outside entities. Your entry is limited to 55 characters.

Principal Investigator's and Grants Managers should carefully review and follow all SF-424 Instructions and requirements prior to submitting proposals.

NOTE: Many proposal instructions have been updated, and applicants should check federal sponsor websites frequently for changes to Notices of Funding Opportunities (NOFOs) and guidance to ensure they are following the most recent versions. 

Foreign Component: (NIH definition)

The performance of any significant scientific element 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 f unds are expended. 
Activities that would meet this definition include, but are not limited to,
 

  1. the involvement of human subjects or animals
  2. extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, or similar activities, or
  3. 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; or
  • receipt of financial support or resources from a foreign entity.

Foreign travel for consultation is not considered a foreign component. (See NIH Grants Policy Statement: 16 Grants to Foreign Organizations, International Organizations, and Domestic Grants with Foreign Components).