NIH: Does work outside of the U.S. require prior approval?

Foreign components are defined as a significant scientific element or segment of a project outside of the United States.  work performed by a researcher in a foreign location qualifies as a , whether or not NIH funds are expended.

All foreign components must receive NIH prior approval. If a PI determines that a portion of the project will be conducted outside of the U.S., determine if it is considered significant and secure NIH prior approval via OSP.

What do I do if the work is significant?

If the work is considered :

• Draft a prior-approval request for the activity including the location on department letterhead
• Address the request to the NIH Grants Management Specialist (GMS)
• Forward the request to OSP
• OSP will submit the formal prior approval request to NIH

Failure to achieve explicit NIH prior approval for foreign components may result in return of funds to NIH, termination of the award, or other measures as determined by NIH.

Other federal sponsors have similar requirements. Please check your award before proceeding with a foreign component.

NIH released policies regarding a new structure for projects with international collaborators. See .

Related Resources

• NIH: Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components
• NIH:
• NIH: Other Support FAQ:
• UW FAQ: Is it considered prior approval when I report upcoming work in a foreign location within my RPPR and receive continuation funding for the next year?

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