On May 12, 2026, the NIH issued an update reaffirming its enforcement of research security and transparency. As part of this initiative, the NIH is actively auditing publications to identify unapproved "foreign components.”
While the definition of a foreign component has not changed (per NIH FAQ), NIH is placing a heightened focus on international publications and co-authorships as a mechanism to identify possible foreign components. Because the regulatory landscape surrounding international collaboration is highly complex, please review the following operational guidance. Please understand that this is OSVPR’s best good faith attempt to offer guidance. We will communicate updates if and when things become clearer.
What do I need to do differently?
- Do Not Respond to the NIH Directly: If you receive an inquiry from your NIH Program Officer or Grants Management Specialist regarding a foreign co-author, a foreign affiliation on a publication, or an unapproved foreign component, do not respond on your own. Forward it immediately to Robin Riglin (rbs15@psu.edu) and the Office of Sponsored Programs (OSP) osp@psu.edu. We will work with you to draft an appropriate, compliant response.
- Add Author Affiliation Notes: If a co-author did their work in the U.S. but now holds a foreign affiliation, explicitly state this in the publication’s author notes. (A copy/paste template is available on OSP's webpage, Navigating NIH Foreign Components).
- Seek Prior Approval: If you are planning a new collaboration that meets the definition of a foreign component, contact your College Research Office immediately to initiate a formal request.
- Consult OSP When Uncertain: If you are unsure if a minor consultation has evolved into a foreign component, read our scenario-based FAQs or reach out to OSP.
- Review guidance and FAQS on our website: We have created a comprehensive webpage to help you navigate these requirements. Please review it to identify what constitutes a foreign component, understand whether to disclose an international collaboration for prior approval or as Other Support, and read our scenario-based FAQs: Navigating NIH Foreign Components.
If you have questions after reviewing the website, please reach out to osp@psu.edu.