NIH Update: Foreign Justification and Foreign Components
NIH proposals with foreign components encouraged to submit a foreign justification
Quick Summary
- Since 2019, a foreign justification has been required for all NIH proposals that include a foreign component.
- Due to increased scrutiny of foreign influence in federally funded research, PDS recommends that you declare all possible foreign components at the time of proposal submission.
- NIH defines a “foreign component” as the “performance of any aspect of a project outside the U.S. either by the grantee or by a researcher employed by a foreign institution, whether or not NIH funds are expended.”
What is a foreign justification and why do I need one?
NIH began requiring a foreign justification document in 2019. Recently, the Sponsored Programs Office at UC Davis has found that NIH is now flagging applications when Foreign Justification attachments are missing, regardless of whether a foreign component or collaborator will receive funds from the NIH award and for relationships that don’t meet the strict definitions (listed below). We wanted to clarify what the purpose of the foreign justification is, as well as how and where to include it in your proposal.
What is a foreign component?
Any NIH proposal involving a foreign component requires a Foreign Justification document. NIH defines a “foreign component” as the “performance of any aspect of a project outside the U.S. either by the grantee or by a researcher employed by a foreign institution, whether or not NIH funds are expended.”
Activities that meet this definition could include:
- 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
- The involvement of human subjects or animals at a foreign site.
- Extensive foreign travel by grantee project staff for data collection, surveying, sampling, and similar activities (Note: Foreign travel for consultation is not considered a "foreign component").
- Any activity that may impact U.S. foreign policy through the involvement of grantee project staff in the affairs or environment of the foreign country.
IMPORTANT: Due to NIH's increased scrutiny of foreign influence on federally funded research, the Proposal Development Services team recommends that you declare all possible foreign engagements and relationships that relate to the applicants' past, current, and planned projects at the time of proposal submission. This will allow the cognizant Program Officer and Grants Management Specialist to review your applications fully and to identify any foreign components. NIH program staff will consider whether this work would meet the threshold for being considered an NIH-defined foreign component.
What should I submit if my project may include a foreign component?
On the R&R Other Project Information Form, Question #6 asks “Does this project involve activities outside of the United States or partnerships with international collaborators?” If you check “Yes” to Question 6, then you must include a “Foreign Justification” attachment in Field 12. Other Attachments. Name the file “Foreign Justification” and include a title at the top of the document that says, “Foreign Justification.”
If applicable, you might also need to include a letter of support from a foreign collaborator.
What do I include in the Foreign Justification attachment?
Your justification should describe, in a paragraph or two, any characteristics of the applicants' current/past/planned projects that involve or have the potential to involve a foreign component. Include the reasons why the resources or personnel are more appropriate than a domestic setting.
The Proposal Development Services team has a template available, and we are happy to review your draft “Foreign Justification” document at any time (pds@ucdavis.edu).
While funded collaborations are more straightforward to describe, here are some examples of justifications for UNPAID collaborations and other relationships that may not meet the strict definition of a foreign component:
Example | What to include in your justification |
| You have an unpaid collaborator in another country who will be providing advice on a technique you plan to use. | Explain why this person is the most qualified to provide this information, and clearly state that there will be no funds transfer. Be sure to mention whether any products, such as publications, might result from the collaboration. |
| One of your key personnel, who is full-time employed at UC Davis, has an unpaid joint appointment at a foreign university or company. | Explain the details of the appointment, including whether that appointment will have any impact, direct or indirect, on the proposed project or vice versa. This could include intellectual property from that appointment that would influence the conduct of this project, or any results of this project that would be used in the future in the conduct of work at the foreign institution. |
| One of your key personnel, who is full-time employed at UC Davis, has grant funding from a foreign sponsor, including summer salary. | Explain the objectives and scope of that project and the salary arrangement, and the extent of overlap, if any, with the current project. Describe whether there will be any products that might result, such as publications or patents, that could be jointly attributed to both sources of support. |
Are there other sections of my proposal where I need to declare foreign components?
- Budget Justification: If any funds are being spent on a foreign collaboration, including consultant funds to a foreign collaborator, international travel, or purchase of equipment from an international vendor, ensure that you fully justify those costs in your budget justification. For example, for foreign travel you should provide sufficient details regarding the location and need as it pertains to your proposal.
- Letters of Collaboration: If you plan to work with an international collaborator, whether paid or unpaid, obtain a letter of support from that individual or organization that explains their role in the project and any arrangements for the transfer of funds, knowledge, or materials. Make sure they acknowledge whether collaborative publications or products are likely outcomes of the arrangement.
- Biosketch and Other Support: If any key personnel have a joint appointment or funding from foreign entities, those arrangements should be listed in the Biosketch (appointments) and Other Support (current projects).
Inside Higher Ed: Agencies Share New Guidance on Foreign Threats at U.S. Colleges
According to this August 2025 Inside Higher Ed article, the joint federal partners bulletin, “Safeguarding Academia," encourages colleges and researchers to be transparent about who is involved in a research project, noting that "failing to disclose foreign collaborations could lead to sanctions."
Researchers are encouraged to do their due diligence on any potential collaborators and use cybersecurity best practices.
Will a foreign component make my proposal less competitive?
It is unlikely that foreign collaborations will affect the review of your proposal. However, you should carefully review your funding opportunity announcement and agency policies to determine if foreign collaborations or activities are permitted.
At this time, NIH supports foreign components in awards, whether paid or unpaid. While there have been recent updates to policies and practices utilizing foreign subawards, funded foreign subawards are still supported when well justified.
The policies referenced in NIH notice NOT-OD-25-104 apply to foreign subawards and do NOT apply to unfunded foreign collaborations, funds provided to support foreign consultants, or purchasing unique equipment or supplies from foreign vendors. Thus, these arrangements are allowable, and also will be supported when well justified.
Resources
- Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components – Notice Number NOT-OD-19-114, Release Date July 10, 2019
- Updated NIH Policy on Foreign Subawards - Notice Number NOT-OD-25-104, Release Date May 1, 2025
- Updated Implementation Guidance of NIH Policy on Foreign Subawards for Active Projects - Notice Number NOT-OD-25-130, Release Date July 18, 2025
- Safeguarding America - Bulletin, August 22, 2025
- Agencies Share New Guidance on Foreign Threats at U.S. Colleges - Inside Higher Ed article, August 27, 2025