Trainings & Courses
Research Integrity
Policies and resources at Penn related to the ethical principles, values, and practices of research conduct and the dissemination of research findings.
Top Resources for Research Integrity
Policies & Procedures
Procedures Regarding Misconduct in Research for Nonfaculty Members of the Research Community.
Policies & Procedures
Financial Conflicts of Interest in Research Program
Trainings & Courses
Philadelphia Symposium on Research Credibility and Excellence 2018
Trainings & Courses
New to Sponsored Projects at Penn?
First steps and essential training for the administrative management of research projects at Penn.
Frequently Asked Questions
What are some examples of a ‘significant element of a project’ when making determinations regarding a foreign component?
When making determinations about significance, the element of the project that is being conducted outside of the United States should be evaluated within the context of the project as a whole. 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
Does work being conducted in the United States ever count as a foreign component?
Generally, no.
I have a collaborator from another country who will work in my NIH-funded laboratory on my NIH project but receive no salary from my NIH grant. Is this considered a foreign component?
No, a “Foreign Component” exists only if the research activities occur outside of the United States.
I am the PI on an NIH grant to a domestic university. I have a visiting post-doctoral fellow in my lab, who works on my NIH grant and does all of his/her work in the United States. The fellow’s salary is paid by a foreign government. Is this a foreign component?
In general, no. The first step in determining whether research constitutes a foreign component is to evaluate whether a portion of the research is being conducted outside of the United States. In this case, since all of the work is being conducted in the US, there would be no foreign component. However, this must be reported as Other Support. All in-kind resources, which includes visitors or employees who are paid directly by outside resources, should be disclosed as Other Support.
I am a PI on an NIH award to a domestic university. I will have a visiting fellow joining my lab whose salary will be supported by a foreign university. Do I need NIH prior approval before the fellow can work on my NIH funded research?
Since specific circumstances may vary, it would be best to discuss with NIH Program Officer.