International travel in proposals may qualify as a foreign component per NIH, affecting compliance in SpartaGrants.
Understanding foreign components
- What IS a foreign component? Examples include:
- Subawards to foreign entities
- Co-authored collaborations with foreign investigators
- Using foreign facilities or equipment
- Support or resources from abroad
- Data collection or fieldwork outside the U.S.
- Human or animal research abroad
- Activities impacting U.S. foreign policy
- What is NOT a foreign component?
- International travel for meetings, conferences or consultations do NOT qualify as a foreign component
What does this mean for a proposal?
To avoid compliance issues and delays, confirm the status early and accurately by following these guidelines and tips:
As a reminder, CWRU International Travel Registration is still required for all international travel, regardless of foreign component status. Each individual traveling outside the United States must complete registration prior to departure.
- For all proposals regardless of status
- Review SpartaCompliance help text
- Consider the entire scope of international activities, not just travel.
- Collaborate with the PI to identify activities abroad that may be foreign components.
- Confirm correct Foreign Component status and ensure consistent answers in SpartaGrants and SF424 forms.
- Escalate any uncertainty early to avoid mistakes.
- If international travel MEETS foreign component requirements
- Mark “Yes” for the Foreign Component question in both the Sparta Grants Funding Proposal Compliance Question and the SF424 Application.
- Submit the International Agreement Form to receive approval from International Relations.
- If international travel DOES NOT MEET foreign component requirements and no other foreign activities are included in the proposal,
- Mark “No” for the Foreign Component question in both the Sparta Grants Funding Proposal Compliance Question and the SF424 Application.
- International Relations approval is not required, so the International Agreement Form does not need to be submitted.
Questions? Review PASA Guidance on International Travel.