The Louisiana Biomedical Research Network (LBRN) would like to share an important reminder regarding National Institutes of Health (NIH) policy on foreign components associated with INBRE-supported activities.

Under the current NIH Notice of Funding Opportunity (PAR-23-100 https://grants.nih.gov/grants/guide/pa-files/PAR-23-100.html), foreign components are not allowed. The NIH Grants Policy Statement defines a foreign component as any significant scientific element or segment of a project conducted outside of the United States or involving a researcher affiliated with a foreign organization, regardless of whether grant funds are used.

Examples of activities that may be considered a foreign component include:

– Collaboration with investigators at foreign institutions that may result in co-authorship
– Use of facilities or instrumentation located outside of the United States
– Receipt of financial support or other resources from a foreign entity
– Data collection activities conducted internationally

NIH has recently increased enforcement of this policy (see NOT-OD-26-026 https://grants.nih.gov/grants/guide/notice-files/NOT-OD-26-026.html).

What This Means for LBRN Investigators
– Publications supported by LBRN funding must appropriately acknowledge the grant
– Publications that include co-authors affiliated with foreign institutions may be considered to involve a foreign component and may not be allowable under LBRN-supported activities
– LBRN funds may not be used to support any activity or publication involving an unapproved foreign component, regardless of acknowledgment
– Investigators should carefully review all collaborations and resulting publications to ensure full compliance with NIH policy prohibiting foreign components under the current funding opportunity

LBRN will align with this policy moving forward. We encourage all investigators to carefully evaluate current and planned collaborations to ensure compliance with NIH requirements.

If you have questions regarding this guidance or need assistance evaluating a collaboration, please contact the Louisiana Biomedical Research Network (LBRN) Administrative Core at lbrn@lsu.edu

⚠️ Important Notice

Effective immediately, publications acknowledging an NIH IDeA-funded award that include a coauthor affiliated with a foreign institution may require prior approval from NIGMS. LBRN investigators, Project Leaders, Pilot Project Leaders, Research Core Directors, and research core users should review the guidance below before submitting manuscripts or initiating collaborations involving foreign institutions.

Background

The National Institutes of Health (NIH) has recently reemphasized its policy regarding Foreign Components of NIH-funded research. Under this guidance, collaborations involving investigators affiliated with foreign institutions may constitute a foreign component requiring prior NIH approval.

This reminder is intended to help LBRN investigators comply with current NIH and NIGMS requirements.

Publications with Foreign Coauthors.

If a publication:

acknowledges an NIH IDeA-funded grant, and includes a coauthor affiliated with a foreign institution, the collaboration may require prior approval from NIGMS before publication.

Investigators are encouraged to consult with the LBRN Administrative Core before proceeding if there is any uncertainty.

Guidance for Research Core Users:

NIGMS recognizes that this policy may create challenges for investigators who utilize institutional research cores.

For investigators who use an LBRN-supported research core on a fee-for-service basis, NIGMS recommends acknowledging the core rather than the grant itself.

Suggested acknowledgement:

“The XXX Core was used on a fee-for-service basis. The Core is supported by the NIH IDeA Program.”

Alternatively, investigators may choose not to acknowledge the IDeA grant when appropriate.

RPPR Reporting for Research Cores

Research Core Directors should continue reporting:

  • Number of publications resulting from core usage
  • Number of users utilizing the core resources

These metrics should be reported separately in the annual Research Performance Progress Report (RPPR).

Guidance for LBRN Investigators

Investigators directly supported by the LBRN award-including:

  • Project Leaders (PLs)
  • Research Project
  • Leaders (RPLs)
  • Pilot Project Leaders (PPLs)
  • Core Directors
  • Other key personnel

should continue acknowledging the NIH IDeA award in publications as appropriate.

However, prior approval from NIGMS must be obtained before initiating collaborations that are expected to result in co-authored publications with investigators affiliated with foreign institutions.

Need Assistance?

If you are unsure whether your collaboration constitutes a Foreign Component or whether prior NIGMS approval is required, please contact the LBRN Administrative Core before submitting your manuscript.

📧 Email: lbrn@lsu.edu

Each report shall also include a completed Information for Subrecipient form signed by the Institutional Authorized Representative, which includes a list of individuals and their associated effort on the project for inclusion in D.1 of the RPPR and confirmation invoicing is current. The Information for Subrecipient form can be downloaded here: INBRE Information for Subrecipient form_for all but LSUHSC-NO.xlsx
For LSUHSC-NO: The Information for Subrecipient form also requires Subrecipient to certify whether there have been changes in Other Support for key personnel since the last reporting period. An updated Other Support form is required if there have been changes. The Information for Subrecipient form can be downloaded here: INBRE Information for Subrecipient form_ LSUHSC-NO only.xlsx