Help/FAQ

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Some of the data fields in the 424 (R&R) do not really apply to foreign organizations. How will this be handled?

For some of the data, special instructions are included in the Application Guide for foreign organizations.

Are foreign organizations required to obtain a DUNS number and register in SAM?

NIH has required all foreign and domestic organizations applying for NIH grants to have a DUNS number since October 1, 2003, and an active SAM registration is required for all foreign and domestic organizations applying electronically (through Grants.gov) for NIH grant support. These requirements for applicant organizations have not changed except that the SAM registration requirement is now extended to all submissions—paper and electronic.

Are foreign grantees required to report executive compensation data under FFATA?

The requirement for FFATA Executive Compensation reporting applies to both foreign and domestic grantees, as well as their subrecipients. However, many foreign NIH grantees and subrecipients receive only small amounts of Federal funding and will not have reached the following levels in the previous fiscal year that require executive compensation reporting:

  • 80 percent or more of the annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, and
  • $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act.

In cases where a foreign institution receives significant Federal funding (as listed above), they are required to report executive compensation information under FFATA the same as U.S. domestic institutions.

Does the 2011 revised financial conflict of interest regulation apply to foreign institutions and international organizations? (Institution)

Yes. The regulation applies to any Institution (i.e., foreign or domestic) that applies for or that receives NIH research funding by means of a grant or cooperative agreement as either a prime awardee institution or a subrecipient institution.

How do I know if a foreign organization is eligible to apply?

Each funding opportunity has a section for Eligibility. In that section there will be a clear statement about whether foreign institutions are eligible to apply

Where can I find NIH sample biosketches?

The samples provided are simply examples of compliant biosketches. Applicants must follow application guide instructions for pdf attachments (font, paper size, margins, etc.), as well as, the biosketch instructions themselves.

Biosketches created using SciENcv conform to all the application guide instructions and format requirements, though there are slight differences from the provided samples. Collapse

Can I update a biosketch post-submission to include new articles just accepted for publication or non-traditional application materials not previously available?

No. A new biosketch attachment is only allowed post-submission if it is related to a change in senior/key personnel due to the hiring, replacement or loss of an investigator. When allowed, the new format must be used on/after May 25, 2015. Under some circumstances, news of a late-breaking article can be submitted following the guidelines in the Post-Submission Application Materials policy (see NOT-OD-16-130).

May foreign work be proposed on an SBIR or STTR application?

In rare and unique circumstances, for example, if a supply or material or the study design (e.g., patient population) is not available in the United States, NIH may allow a small portion of the research /R&D work to be performed by a foreign organization. Foreign involvement will be considered on a case-by-case basis and must be thoroughly justified in the application. Applicants should discuss their unique situations with NIH program staff prior to submission of the application. Whenever possible, non-SBIR/STTR funds should be used for other work outside of the United States that is necessary to the overall completion of the project.

Do Key Personnel on foreign awards or on foreign subcontracts have to comply with the Human Subjects education requirement?

Yes. The education requirement applies to all investigators involved in the design or conduct of research involving human, including foreign awards and subcontracts. Foreign certification and documentation of the required education in languages other than English are acceptable.

If the grantee organization has difficulty obtaining documentation that Key Personnel on foreign subcontracts have received the required education, NIH staff may consider issuing awards that restrict third party participation until this documentation is provided to NIH. This will streamline issuing awards in situations where third party participation is not essential to the start of the project. See the September 5, 2001 NIH Guide Notice for additional information.

If an animal activity will be performed outside of the US (either by a foreign awardee or by a foreign institution as a subproject for a domestic awardee), is the awardee’s IACUC required to review and approve that activity?

When the awardee is a domestic institution (i.e., domestic award with a foreign component), PHS animal welfare requirements are applicable. Accordingly, the awardee remains responsible for animal activity conducted at a foreign site and must provide verification of IACUC approval. That approval certifies that the activity, as conducted at the foreign performance site, is acceptable to the awardee. The awardee IACUC may accept, as its own, the approval of a foreign entity's IACUC; however, the awardee IACUC remains responsible for the review. Additionally, the foreign institution must complete the Animal Welfare Assurance for Foreign Institutions (Foreign Assurance) available from OLAW. This document certifies that the institution will comply with the applicable laws, regulations, and policies of the jurisdiction in which the research will be conducted, and that the institution will be guided by the International Guiding Principles for Biomedical Research Involving Animals . OLAW encourages, but does not require, foreign institutions to use the standards in the Guide . If the prime awardee is a foreign institution, IACUC approval is not required.

If foreign travel is involved, can the attendees use any airline?

No, an American flag carrier must be used if available. For more information about travel, visit http://grants.nih.gov/grants/policy/nihgps_2001/part_iia_4.htm#Travel.

What happens to equipment when the PD/PI moves to another organization?

The grantee organization is the legal entity to which a grant is awarded. When the PD/PI moves to another organization, the following options apply (1) The grantee organization may request continuation of the project under the direction of an alternate PD/PI. If the alternate PD/PI is approved by NIH, the grant will continue and thus title to the equipment purchased under the grant will remain with the original grantee organization.

(2) The organization may relinquish its interests and rights in the grant to the PD/PI's new organization. If the new organization is approved by NIH to continue the grant activity, then the grant will be awarded and any equipment purchased with grant funds and still needed for the grant project would be expected to transfer to the new grantee organization, which would assume title. If the original grantee does not voluntarily agree to relinquish equipment with the grant, HHS may require transfer of the equipment as specified in 45 CFR Part 74.34(h).

(3) If an alternate PD/PI is not accepted by the NIH (or no alternate is nominated), and the original grantee refuses to relinquish its rights in the grant to the new organization (or if the new organization is not accepted by NIH to continue the research), then the grant will be terminated. Title to equipment will remain with the original grantee organization, subject to disposition or use as described in 45 CFR Part 74.34. The PD/PI's new organization may submit a new application through the regular NIH peer review process to request support for the research.

The transfer of a grant to a foreign organization or between foreign organizations requires the additional approval of the National Advisory Council/Board of the awarding NIH IC