Does adding a foreign component require NIH approval?

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Multiple Choice

Does adding a foreign component require NIH approval?

Adding a foreign component to an NIH-funded project is treated as a change in the approved scope of the project, and it typically requires prior NIH approval. NIH grants are issued with specific aims, a defined budget, and an approved plan. Bringing in work conducted at a foreign site or with foreign collaborators changes how the project is carried out, who is performing the work, where the work occurs, and may introduce new compliance considerations (such as regulatory, export control, data handling, and human subjects protections even if those subjects aren’t involved directly). Because of these potential changes to scope, oversight, and risk, NIH requires a formal request and written approval before the foreign component can proceed or funds are expended. This doesn’t hinge on whether the foreign work costs more than a threshold or whether human subjects are involved. Even without those factors, the addition of a foreign component generally triggers prior approval to ensure all regulatory and administrative implications are properly managed.

Adding a foreign component to an NIH-funded project is treated as a change in the approved scope of the project, and it typically requires prior NIH approval. NIH grants are issued with specific aims, a defined budget, and an approved plan. Bringing in work conducted at a foreign site or with foreign collaborators changes how the project is carried out, who is performing the work, where the work occurs, and may introduce new compliance considerations (such as regulatory, export control, data handling, and human subjects protections even if those subjects aren’t involved directly). Because of these potential changes to scope, oversight, and risk, NIH requires a formal request and written approval before the foreign component can proceed or funds are expended.

This doesn’t hinge on whether the foreign work costs more than a threshold or whether human subjects are involved. Even without those factors, the addition of a foreign component generally triggers prior approval to ensure all regulatory and administrative implications are properly managed.

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