In most cases, or unless specifically required by the funding agency, there is no reason to disclose participation of foreign students or postdocs on sponsored research, particularly if all work will be performed in the United States. However, there may be cases where working with a student or postdoc might be considered a “foreign component” if that student or postdoc is performing effort in a foreign country. NIH defines a foreign component as “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.” Another consideration would include disclosure of such scenarios as a foreign student, postdoc, or visiting scholar participating in the project even if they are not receiving financial support and/or tuition reimbursement from the project, particularly if the collaboration will lead to a foreign participant appearing as a co-author on a publication that arises from or references U.S. government funding for the underlying research. The NIH has indicated that, if a post-doc has returned to his/her home country and is working remotely due to COVID-19, this scenario does not represent a “significant scientific element” that would required disclosure as a foreign component.

The University is using recommendations in the Dec. 2018 report issued by the NIH Working Group for Foreign Influences on Research Integrity to help inform its decision-making in this arena. Among the suggestions made by the working group to grantee institutions are (1) to update policies and forms to make requirements more explicit, and (2) to clarify when nondisclosure may constitute research misconduct. This webpage was created, in part, to implement those suggestions. 

Yes. Prior to award, the Sponsored Programs Administration (SPA) may be able help correct proposals where disclosures have been omitted or contain inaccurate information. Once an award has been made, the NSF in particular has revised award terms that require us to report previously undisclosed current support or in-kind contribution(s) within 30 days of identifying the oversight. Please contact the SPA at for assistance with correcting applications.



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