Dear Alliance Investigators,
The Alliance would like to share important updates and requirements regarding the NIH policy on foreign components associated with Alliance-supported activities. The NIH Grants Policy Statement defines a foreign component as the performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended
WHO DOES THIS POLICY APPLY TO:
The policy and requirements described here therein apply to all Alliance-supported investigators, irrespectively of their institutional affiliation.
This includes:
- PIs, MPIs, or Key Personnel in any study receiving services by any of the Alliance Cores and Resources
- Current awardees of Research Training Opportunity Program (RTOP), Mentor-Mentee, or Early Stage Career Investigators Development (ESCID) Program
- Current awardees of HR grants (Pilot Projects, Developmental Projects, and Multi-Site Collaborative projects)
ALLIANCE POLICY FOR DOMESTIC-ONLY RESEARCH
- All research activities, data collection, and data analysis related to ALLIANCE-supported research will be conducted exclusively within the United States or its territories (e.g., Puerto Rico, USVI).
- Any collaboration with individuals affiliated with a foreign institution that results in co-authorship constitutes a foreign component and is strictly prohibited without prior approval from NIH or the appropriate federal agency.
- NO ALLIANCE funds will be transferred via sub-contract or any other mechanism to an institution or individual in a foreign country.
- This excludes fee-for-service activities such as learning new techniques, sample and data analysis, workshops, etc. These activities cannot result in co-authorship.
- PIs are required to submit prior approval requests for any publication co-authored with individual(s) affiliated with a foreign institution(s), even if the collaboration does not involve exchange of NIH funds.
- Per NOT-OD-26-026, prior approval requests must be initiated and submitted by a Scientific Officer for the recipient organization.
- In addition to noting the foreign site and the name of the foreign investigator, the prior approval request should provide information about the nature of the research being conducted; why the involvement of the foreign site is necessary; and whether any data will be transferred
Please review current and planned collaborations, to ensure compliance with this policy. Failure to comply with this policy will result in suspension of Alliance support and services until proper corrective actions have been taken.
IMMEDIATE ACTION REQUIRED:
- UPR-MSC investigators must complete the Alliance certification even if they have already submitted the UPR-MSC certification.
- Annual re-certification will be required
- Complete the Condensed Training Modules in Research Security (RST) offered by the NSF SECURE center. Once completed, please upload the certificate.
- Annual re-certification will be required.
Failure to provide the above certifications will result in suspension of Alliance support effective May 25th, 2026, until proper actions have been taken.
If you have questions about this guidance or need assistance evaluating a collaboration or submitting a prior approval request, please contact the Alliance.
Thank you for your attention to this important issue and please keep attentive to Alliance communications and website for any updates.
The Alliance AC
