Foreign Components of research include locations outside of the U.S. where a significant scientific element or segment of a project is performed, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended outside the U.S.
Principal Investigators should review current projects to ensure that all Foreign Components have been disclosed through progress reports and final technical reports, and to obtain prior approval when adding a Foreign Component to an existing federal award. All new proposals must include a clear description of all Foreign Components. Sponsors have varying requirements to disclose foreign components, so it is important to understand each sponsor's proposal instructions before submission.
Activities that meet this definition (per NIH) include, but are not limited to:
-
the involvement of human subjects or animals at a foreign location;
-
extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities at a foreign location;
-
collaborations at a foreign site anticipated to result in co-authorship;
-
receipt of financial support (including travel support) or resources from a foreign entity; or
-
use of facilities or instrumentation at a foreign site.
Foreign travel for consultation unrelated to research activities is not considered a Foreign Component.
The Office of Sponsored Programs provides helpful information about disclosures. Please direct all questions related to disclosures to FundingAgencyDisclosures@pitt.edu.