Foreign Components in eRPM

PAF Question 5.13 – Significant Effort Outside of United States

The eResearch Proposal Management (eRPM) system proposal approval form (PAF) has a required question 5.13 that relates to the foreign component of work, or the portion of project work that will be performed outside the United States. If the answer is yes, select the country(ies) from a drop down list. 

eRPM Question 5.13: “Will anyone perform a significant portion of this project outside of the United States?”

Help Text: Answer “Yes” if a significant aspect of the scope of work (SOW) for which U-M is seeking funding will be performed outside of the U.S. It does not matter who will be performing the work outside the U.S. (e.g., a U-M investigator or a collaborator in another country). Nor does it matter who is funding the work, if at all. Funding agencies may require that work performed outside the U.S. be disclosed in the proposal (e.g., NIH requires applicants to disclose “Foreign Components”).

If completing the PAF as a subcontract for U-M, answer the foreign component questions with regard to U-M’s portion of the project.

What makes something a significant element?

The recipient institution should evaluate the element of the project that is being conducted outside of the United States within the context of the project as a whole when making determinations about significance. Some examples of activities that may be considered a significant element of the project include, but are not limited to:

• Collaborations with investigators at a foreign site 
• Use of facilities or instrumentation at a foreign site
• Receipt of financial support or resources from a foreign entity

Examples of foreign components:

• Most instances of co-authorship with investigators at a foreign site
• Collaborations with investigators at a foreign site anticipated to result in co-authorship
• Work conducted abroad: U-M researchers or project staff will travel to a foreign country to collect data, perform experiments or conduct surveys.
• Collaboration with non-U.S. institutions: Parts of the research will be completed at a foreign facility, lab or university (e.g., a co-investigator at the University of Toronto will conduct some lab analysis).
• Data collection at international sites: Gathering samples, recruiting study subjects, or collecting data outside the U.S.
• Use of foreign facilities, equipment or resources: Accessing or utilizing research resources located outside of the U.S.
• Remote access to foreign technology or software: Using technology hosted on servers outside the U.S. that is integral to the project’s aims.

Not generally considered a foreign component:

• Foreign travel for consultation
• A collaborator who moved overseas after the work was completed
• Foreign vendors providing routine services
• Foreign co-author providing minor editorial feedback 

Important Note: If the activity involves significant programmatic involvement or scientific contribution by a foreign entity or researcher, it likely qualifies as a foreign component and must be disclosed in the eRPM system.

For questions about co-authors on papers, reach out to the sponsor’s grants management specialist or program officer to confirm whether or not these individuals need to be listed. When required, disclosure of foreign co-authors to the NIH should occur prior to publication. Other sponsors have not specifically commented on this.

Visitors not funded by PI’s federal agreements

If a laboratory has a visitor who is supported by their home foreign institution and not funded by any of the PI’s federal agreements, project teams will need to account for the visitor as a foreign component for proposals and progress reports if:

• They are performing a significant element of the project and at least some of that work is conducted outside of the United States.
• The collaboration otherwise meets NIH’s definition of a foreign component, including certain collaborations with investigators at foreign institutions that result in co-authorship or involve substantive scientific participation from the foreign site, even when no NIH funds are provided to the foreign institution.

The determination is based on the nature and significance of the scientific collaboration rather than solely on the source of funding or the visitor’s physical location while working in the United States.

NIH’s definition of a foreign component extends beyond foreign subawards and funding arrangements. Activities conducted by, or in collaboration with, investigators at foreign institutions may require disclosure as a foreign component when they represent a significant scientific element of the project, including some collaborations that result in co-authored publications.