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Foreign Components in eRPM

Question 5.13 on the eResearch Proposal Management (eRPM) Proposal Approval Form (PAF) relates to Foreign Components in research, or the portion of project work that will be performed outside the United States. 

InternationalPAF Question 5.13- Significant Effort Outside of United States - FAQs

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, you are asked to select the country(ies) from a drop down list. 

5.13 Question

eRPM Question 5.13:

"Will anyone perform a significant portion of this project outside of the United States?"

Help Text: "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”).

Additional U-M FAQs to Aid in Answering Question 5.13

FAQs

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 anticipated to result in co-authorship

- use of facilities or instrumentation at a foreign site

- receipt of financial support or resources from a foreign entity

Yes,  you should report the visitor as a “Foreign Component” if the individual performed part of the work while in your lab, and/or also made a significant contribution to the project from his/her home institution, or any other foreign location (e.g. collecting data at a foreign site, running samples on instrumentation there, and/or will be a co-author on publications arising from the grant).

Yes. You may not perform a significant scientific element or segment of an NIH-funded project outside the U.S. without prior NIH approval. Per NIH Grants Policy Statement 8.1.2.10 “Adding a foreign component under a grant to a domestic or foreign organization requires NIH prior approval.”

The NIH definition of “foreign component” states that “extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities” is a “foreign component.” 

Please reach out to your NIH 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. Should you have questions, please consult your ORSP Project Representative.

Just because your sponsor is a foreign entity doesn’t mean your project has a foreign component. It’s where the work is performed that determines whether there’s a foreign component. 

 

This is not performance of a portion of the project and you should answer "no" unless the work is performed in a foreign country.

Same as above. (See answer to “What if the sponsor is a foreign entity.”)

Questions?

  • If you have questions (that are not related to your school’s or college’s implementation of this policy), reach out to your ORSP project representative.