Department of Energy
The Department of Energy (DOE) reviews materials submitted as part of the application process, including Current and Pending (Other) Support and in and in Financial Conflicts of Interest (FCOI) disclosures | FCOI Decision Tool.
Research Security Training
From May 1, 2025 mandatory Research Security Training (Job Aid) is required for all Covered Individuals prior to proposal submission and annually thereafter. Learn more about the DOE requirement.
National Institutes of Health
The National Institutes of Health (NIH) strongly encourages international collaborations, while at the same time requiring that grant-related documents submitted to the agency contain information that is true, complete, and accurate and assuring that there is no scientific, budgetary, or effort overlap and no inadequately managed financial conflict of interest. Learn more on the NIH website.
NIH reviews Biographical Sketches, Other Support and Financial Conflicts of Interest (FCOI) disclosures of senior/key personnel related to foreign interference | FCOI Decision Tool. The NIH Decision Matrix for Assessing Potential Foreign Interference (PDF) is used for initial NIH assessment and notes the following factors.
Mandatory Training
Beginning October 1, 2025, prior to submitting Other Support reports, everyone identified as senior key personnel must complete Other Support Training. Other Support reporting may be required with certain NIH applications or as part of Just-in-Time (JIT) requests or Research Performance Progress Reports (RPPR).
This requirement can be met by completing one of the options below.
- Research Security at the University of California (Job Aid)
- NSF Consolidated Research Security Training Module (approx. 1 hour) available on the NSF SECURE Center site
- The “UC Ethics and Compliance Briefing for Researchers” (approx. 1 hour)
NIH will require senior key personnel complete Research Security Training (RST) before submitting applications due on or after May 25, 2026. This requirement will also satisfy the Other Support training and can be met by completing one of the options below.
- Research Security at the University of California (Job Aid)
- NSF Consolidated Research Security Training Module (approx. 1 hour) available on the NSF SECURE Center site
Assessing Foreign Influence
When determining whether mitigation is required, NIH reviews the submitted materials for participation foreign talent recruitment programs (FTRPs) (definition), funding from foreign sources, and affiliations with foreign institutes or entities.
International Collaborations
New International Collaborations Application Structure
Effective for applications due on or after May 1, 2025, NIH is no longer accepting new applications requesting funds to support foreign components using the traditional grant subaward/consortium structure (NOT-OD-25-104). Instead, NIH will use a new application structure that would directly fund foreign entities collaborating with lead domestic entities (NOT-OD-25-155).
Competing applications requesting funding for foreign components will only be accepted for a NOFO that supports the new PF5 or UF5 activity code, or another complex mechanism activity code that supports the International Project component type. Applications must be submitted using the multi-project funding opportunity (see PA-26-002).
Each foreign collaborator proposed for funding should have its own unique International Project component included in the application. If your application includes multiple foreign collaborators from different institutions, include a separate International Project component for each one.
Minimum Application Requirements
- Overall Component that addresses the project's overall objectives as a collaboration
- Research Project component that addresses the scientific and technical directions of the project
- International Project component that addresses the foreign collaborator's role on the project
- Letter from each foreign organization's AOR acknowledging that they will fill the role of recipient organization for the disaggregated award
Awards
The International Project components will be separated from the domestic portion. Each will have distinct grant numbers. The domestic organization will be awarded using the PF5 or UF5 activity code, and the foreign organizations using the RF2 or UL2 activity code.
NIH has the ability to fund all, none, or some of the components of the PF5 application, based on the assessment of the technical merit, materials submitted through the JIT process, and agency priorities. The system disaggregation of a PF5 application should not be considered a commitment to funding.
Reporting
Each recipient is responsible for their own financial reporting. NIH will provide future guidance on progress reporting and other details, which will be included in the Notice of Award terms and conditions.
Resources
- NIH Foreign Subaward Policy FAQs
- PA-26-002: NIH Collaborative International Research Project (Parent PF5 Clinical Trial Optional)
- OCGA Hosted Review Session (April 16, 2026) (UCLA Box Login Required)
- NIH Nexus: What Are the Components of a Collaborative International Research Project (PF5) Application and What Should Be Included?
- NOT-OD-25-104: Updated NIH Policy on Foreign Subawards
- NOT-OD-25-155: New Application Structure for NIH-Funded International Collaborations
- NIH Extramural Nexus: Announcing New Application and Award Structure for NIH-Funded International Collaborations (Replacing Foreign Subawards)
- NIH Collaborative International Research Project (Parent PF5 Clinical Trial Optional)
- NIH FAQs: Foreign Subaward Policy
- Determining Whether NIH Prior Approval is Required for a Foreign Component
- UCLA Guidance on the Interim NIH Foreign Subaward Policy: Awards received on/before September 24, 2025 and existing awards with human subjects at foreign sites
National Science Foundation
NSF encourages international collaboration while placing a critical emphasis on research security. View the Research Security at the National Science Foundation (NSF) for more resources and information, including case studies.
NSF requires senior/key personnel to disclose foreign involvement as part of the proposal package (Collaborator and Other Affiliations, Biographical Sketch, and Current and Pending (Other) Support), and in Financial Conflicts of Interest (FCOI) disclosures | FCOI Decision Tool, and to certify that they are not party to a malign foreign talent recruitment program.
See Important Notice No. 149: Updates to NSF Research Security Policies for more information.
Research Security Training
From October 10, 2025, mandatory Research Security Training is required for everyone identified as senior key personnel prior to proposal submission an annually thereafter.
This requirement can be met by completing one of the options below.
- Research Security at the University of California (Job Aid)
- NSF Consolidated Research Security Training Module (approx. 1 hour) available on the NSF SECURE Center site
