Foreign Component Policy

VBRN investigators are required to adhere to current NIH and NIGMS policies regarding foreign collaborations and publication practices under INBRE-funded awards. Importantly, any collaboration with investigators at a foreign institution that is anticipated to result in co-authorship is considered a foreign component under the NIH Grants Policy Statement and is not allowable without prior approval from NIH**.

Since 2003, NIH awards with publications coauthored with investigators from foreign institutions have required prior approval. NIH has recently increased enforcement of this policy. The INBRE NOFO (PAR-23-100), specifically states that, “foreign components, as defined in the NIH Grants Policy Statement, are not allowed.”

The NIH Grants Policy Statement defines foreign components as:

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 grant funds are expended or not. 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, and 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
• receipt of financial support or resources from a foreign entity

Foreign travel for consultation is not considered a foreign component.

**If requesting prior approval from NIH contact vbrn@uvm.edu. For VT-INBRE-supported investigators for whom international collaboration is integral to their broader research programs, any planned publication involving co-authorship with individuals affiliated with foreign institutions will require prior approval from NIH. A request for prior approval is to be submitted by VBRN’s signing official (SO). The request must include: (i) the name of the foreign investigator(s) and institution(s); (ii) a detailed description of the proposed research activity; (iii) a clear and compelling justification for the necessity of foreign involvement; and (iv) disclosure of any actual or anticipated transfer of data or materials. Approval is not guaranteed and will be granted only under exceptional circumstances consistent with NIH policy.