International Research Security Policy

In collaboration with the Federal Demonstration Partnership (FDP) Research Security Subcommittee, NIH has released a FAQ document on Co-authorship and Foreign Components. The FAQs are based on questions and answers provided during the session "Co-authorship and Foreign Components: A Discussion with NIH Extramural Leadership" held on September 15, 2026, as part of FDP's virtual meeting. The FAQs use a variety of scenarios to clarify when foreign co-authorship or collaboration would likely be considered a "foreign component," requiring NIH prior approval. NIH notes that most foreign co-authorship represents a foreign component, and that if a foreign engagement is expected to result in co-authorship, the institution should seek prior approval. The FAQs list exceptions that are not foreign components or collaborations, including informal scientific conversations, one-way transfers of data or materials, peer review, conference participation, and editing conducted by a former U.S. postdoc who has moved abroad.

The National Academies of Sciences, Engineering, and Medicine's National Science, Technology, and Security Roundtable, called for in the Fiscal Year 2020 National Defense Authorization Act, explored issues related to protecting U.S. national and economic security while ensuring the open exchange of ideas and the international talent.

A September 2022 NASA presentation (at 49:32 in the recorded Federal Demonstration Partnership federal agency updates session) in which NASA clarified how it applies the Wolf Amendment restriction. NASA explained that it defines a 'Chinese-owned company' as any company owned by China, or any company incorporated under the laws of China, and that Chinese universities and similar institutions are considered to be incorporated under the laws of China and are therefore subject to the funding restrictions.

Issued May 1, 2025. Prospectively updates NIH policies and practices for utilizing foreign subawards. Per the notice, 'NIH is establishing a new award structure that will prohibit foreign subawards from being nested under the parent grant. This new award structure will include a prime [with independent linked awards] that will allow NIH to track the project's funds individually while scientific progress will be reported collectively by the primary institution under the Research Performance Progress Report.' NIH anticipates implementing the new award structure by no later than September 30, 2025, prior to Fiscal Year 2026. The policy continues to support direct foreign awards and plans to expand this policy to domestic subawards in the future, for consistency.

Issued July 18, 2025 as a follow-up to NOT-OD-25-104. This updated guidance creates an alternative, short-term approach for existing grants and cooperative agreements involving human subjects research (e.g., clinical trials and clinical research) with foreign sites. The alternative approach involves removing a foreign sub-award from the primary award and having it issued as a foreign supplement award.

Issued September 12, 2025, this notice provides additional information on the agency's new process for handling foreign components, as NIH announced in NOT-OD-25-104 that the agency would not issue awards for proposals that include subawards to foreign entities. Under the process described in NOT-OD-25-155, competing applications that include one or more foreign components must submit to a Notice of Funding Opportunity (NOFO) that supports a complex mechanism activity code, including two new international project 'parent' activity codes that NIH is creating: PF5 for grants and UF5 for cooperative agreements.

On September 18, 2025, NIH released additional information regarding the agency's new application and award structure for international collaborations, previously announced in NIH NOT-OD-25-155. In addition to summarizing impacts to proposing/recipient institutions, the announcement provides links to additional information for the four new Activity Codes (grant types) that will be used to facilitate the new application and award process.