A Foreign Component is defined as the existence of any "significant scientific element or segment of a project" outside of the United States.
- Performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
- Performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.
If project staff (including visiting faculty, scientists, etc.) leave the country to return home due to COVID-19 and continue to work on the project, whether paid by the project or not, this could qualify as a foreign component and would require prior approval from the NIH IC.
For Postdoctoral scholars that are required to work on their originally approved work remotely from a foreign country due to COVID-19 travel restrictions, where no grant funds are going to a foreign entity, NIH has determined this scenario does not constitute the performance of a significant element or segment or the project outside the US. Therefore, this is not considered a foreign component and does not require prior approval.
See: NIH NOT-OD-19-114, NIH COVID-19 FAQs
What are some examples of a "significant element of a project" when determining if a foreign component exists?
Evaluate the element of the project that is being conducted outside of the United States within the context of the project as a whole when making determinations about significance. Consider and identify relationships, existing and potential, that may impact research integrity, financial conflict of interest, and/or overlap.
Some examples of activities that may be considered a significant element of the project include, but are not limited to:
- collaborations with investigators at a foreign site anticipated to result in co-authorship
- use of facilities or instrumentation at a foreign site
- receipt of financial support or resources from a foreign entity