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Foreign Components on NIH Proposals

The National Institutes of Health (NIH) has implemented policy updates (NOT-OD-25-104/NOT-OD-25-155) that significantly change how international collaborations are structured in NIH grant applications. NIH will no longer issue subawards to foreign organizations. Instead, applications must use a multi-project structure with an International Project component for each foreign organization. If funded, International Project components will be awarded separately from UF’s award. 

As of January 2026, a PF5 funding opportunity has been released that is to be used when the project includes foreign component(s) (PA-26-002). It is not to be used for projects with only foreign consultants, equipment purchases, or collaborations that do not involve NIH‑funded foreign components.

Submission

  • Follow the Multi‑Project (M) Instructions in the “How to Apply – Application Guide” (Multi-Project Instructions for NIH and Other PHS Agencies). Deviations are only allowed if explicitly noted in the NOFO or an NIH grant notice.
  • Because these are multi-project applications, the NIH ASSIST system needs to be used at UF to submit and track the application.

General Information

  • In the Overall Component, include UF’s vision for the collaboration, goals, the necessity of international collaboration, and coordination plan. Highlight the special research opportunities for the international institution (e.g., unique talent, resources, populations, or environments) not readily available in the U.S. or that augment U.S. resources.
  • Include the foreign component as an International Project component. In the International Project(s), the scope of work, unique attributes, and contributions of each foreign partner should be included and align with the Overall/Research goals. If awarded, an independent grant number will be assigned to the International Project.
  • Do not include subaward/consortium/contractual costs for non‑U.S. entities. Subaward costs are only allowed for U.S. organizations.
  • Answer “Yes” for foreign activity in the Overall component and International Project component.
  • Answer “Yes” for foreign activity in the Research Project component only when the Research Project (not the International Project component) involves foreign activity such as foreign consultants or travel abroad.
  • Attach a Foreign Justification in all components where the answer is “Yes” for foreign activity. The filename must contain “ForeignJustification” (e.g., ForeignJustification_Overall.pdf, ForeignJustification_ResProj1.pdf, ForeignJustification_[site]). If included, the Research Project foreign justification must address only the Research Project’s foreign activities and must not duplicate the justification from the International Project component.

Research Project (UF)

  • Use Component Type “Project” and submit at least one domestic Research Project component led by UF. Additional Research Project components are allowed for complex, interdisciplinary work. If you plan more than one, consult program staff at the relevant NIH Institute/Center to confirm alignment.
  • The Research Project component budget must not include any subaward/consortium/contractual costs for foreign (non-U.S.) organizations. An International Project component must be included in lieu of a foreign subaward. However, this line may be used for subaward/consortium/contractual costs to domestic (U.S.-based) organizations.
  • Since the International Project component funds will be awarded directly to the foreign entity, UF’s budget cannot include indirect costs on the first $50,000 to administer the component.
  • Only the UF portion of the proposal is entered into UFIRST. Both the UF and International Project components are entered in ASSIST.

International Project (Foreign Component)

  • The foreign partner must list its UEI on its own subaward budget form; if it lacks a valid UEI, use the placeholder UEI shown in the “SF424(R&R) Cover (International Project)” section of the NOFO.
  • The foreign partner must be registered in SAM and have an NCAGE code. (Information for Foreign Grants | Grants & Funding)
  • The foreign PI is required to have an eRA Commons account linked to an ORCID ID, as well as use SciENcv to complete Common Forms. (NOT-OD-26-018)
  • The International Project component will require a letter of support from an Authorized Organizational Representative (AOR) of the foreign organization stating they understand that they will become the PD/PI and recipient of a separate award and will complete all required registrations.

Other Information

Please contact DSP at ufproposals@ufl.edu if you have any questions.

Last updated 2/12/26