Foreign Engagement in Federally Funded Research

The U.S. federal government has recently issued a number of new requirements governing collaborations with foreign institutions and the individuals affiliated with them. Understandably, the pace and volume of these changes have created some confusion. Below are answers to the questions we most frequently receive about foreign engagement and the disclosure of that engagement.

Please contact the Office of Research Protections at  ORP_Support@pitt.edu  or the Office of Research Security and Trade Compliance at  researchsecurity@pitt.edu with any questions.

What is a "foreign component," and is it allowed?

The National Institutes of Health (NIH) defines a foreign component as the performance of any significant scientific element of a project outside the United States — by the recipient or by a researcher employed by a foreign organization — whether or not grant funds are spent. Examples include the use of human subjects or animals at a foreign site, a significant scientific contribution (including data analysis) by a foreign-based researcher, extensive foreign travel for data collection, a foreign performance site, or use of a contract research organization abroad. Other agencies apply similar concepts; the National Science Foundation (NSF), for example, requires prior authorization before a significant portion of the work is transferred to another organization.

Foreign components are generally permitted, but any significant component performed abroad must be disclosed prospectively — in the application or through a later prior-approval request (submitted via the Office of Sponsored Programs) — and you must wait for agency approval before that work begins.

Sponsors differ in how they want foreign components disclosed, so review each sponsor’s proposal instructions carefully before submitting. The Office of Sponsored Programs provides more information on disclosures. For questions about funding-agency disclosures, contact FundingAgencyDisclosures@pitt.edu.

How would an agency know a foreign component exists?   

Agencies now monitor publications and scrutinize progress reports, checking whether their grant numbers appear on publications that include foreign authors or institutions. In NOT-OD-26-084 (May 27, 2026), NIH stated that most instances of co-authorship with a foreign author represent a foreign component, and agencies are beginning to require justification when a federal award number appears on a publication with foreign-affiliated authors. Any part of the funded work performed by a foreign colleague or entity — even with no funds transferred — must be pre-approved by the agency.

I am scheduled to travel abroad and would like to work on my federally funded project. Will federal agencies consider this a foreign component that needs to be disclosed and/or pre-approved?   

It depends on the length of your stay, the country you are visiting, and the type of research you plan to conduct while abroad. Some agencies may require disclosure and pre-approval of research in a foreign location, even if it occurs in your hotel room with no contact with collaborators. Typically, short trips of a few weeks that involve limited work on federally funded research activities (e.g., data analysis) without international collaborations are not considered foreign components. However, trips lasting more than a few weeks and/or involving a country of concern (China, Russia, Iran, North Korea, Cuba, or Venezuela) should be discussed prospectively with your federal program official to confirm. The Office of Research Protections and the Office of Research Security and Trade Compliance are also available for advice.

May I share data and collaborate with a former graduate student after they return to their home country?   

It depends on the country involved and the type of data you intend to share.

Some countries are comprehensively embargoed by the United States (Iran, for example), and sharing data or technology with a collaborator located there may require an export license. The Office of Research Security and Trade Compliance can determine whether a license is needed and, if so, help you obtain one.

If your former trainee is employed by an institution on a U.S. Government restricted-party list (such as the Commerce Entity List or the DoD Section 1260H list), some funding agencies restrict or prohibit the collaboration.

Separate restrictions apply to sharing certain data with the six “Countries of Concern” — China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and Venezuela. Under the Department of Justice Data Security Program, transfers of bulk U.S. sensitive personal data and U.S. government-related data to entities or persons affiliated with these countries are prohibited or restricted. NIH separately prohibits institutions located in these countries from accessing its Controlled-Access Data Repositories. Before sharing data with a collaborator in any Country of Concern, consult the Office of Research Protections or the Office of Research Security and Trade Compliance.

Finally, if the collaboration relates to federally funded research, the funding agency will likely view your former trainee’s participation as a foreign component that requires the agency’s prior approval.

Can foreign trainees or visitors collaborate on my federal project?   

Yes, unless your Notice of Award explicitly excludes it. For example, through its Component Decision Matrix (released March 9, 2026), the Department of Defense (DoD) / Department of War (DoW) restricts collaborations on DoD/DoW-funded fundamental research with employees of institutions named on the 13 “Prohibited Entity Lists.”

If a trainee or visitor is supported by their home institution or another external source, that support must be disclosed to the agency as other support (an in-kind contribution). Pre-approval is typically not required, but the support should be acknowledged in your next progress report. When a foreign visitor or trainee contributes to work in your laboratory in Pittsburgh, list the University of Pittsburgh as the performance site on any resulting publication, and use the paper’s acknowledgments and author-contribution sections to make clear where the work was done, so the agency does not treat the contribution as a foreign component.

Will listing foreign co-authors on publications invite scrutiny?   

It may, particularly where a foreign component was not approved in advance. Even so, anyone who meets authorship criteria should be listed; the appropriate response is proper disclosure and approval, not omission of deserving authors. If an agency questions a foreign author, be prepared to state when and where the work was conducted, whether the collaboration is ongoing, and whether federal funds supported research at the foreign location. If the collaboration is ongoing, notify the funding agency (through a request submitted via the Office of Sponsored Programs) and obtain authorization. Agencies may also question prior publications that list foreign authors in articles that cite federal funding.

What must I disclose in my application?   

NIH’s disclosure requirements are described here, and NSF’s here. Other agencies have similar requirements. The proposal must disclose, in the appropriate section (Other Support or Facilities and Resources), all current and pending research funding — domestic or foreign, whether or not it directly relates to the proposed project — as well as in-kind support valued at $5,000 or more that involves a commitment of your time. In-kind support may include equipment, materials, services from external entities, or personnel costs. Your biographical sketch must list all academic, professional, and institutional appointments and affiliations, paid or unpaid, domestic or foreign. The bottom line: disclosure should be broad — over-disclosure is far preferable to under-disclosure.

Disclosure and co-authorship summary by federal agency

Sponsor	Disclosure and Foreign Co-authorship Requirements
DoD / DoW	The 2026 DoW Component Decision Matrix governs how the Department decides whether a fundamental research proposal carries an undue-foreign-influence risk that must be mitigated before an award proceeds. Current participation in a Malign Foreign Talent Recruitment Program (MFTRP) is prohibited outright, and a set of risk indicators, evaluated over a five-year look-back, can trigger a required mitigation plan. Co-authorship is one such indicator: within the past five years, a co-author who is an MFTRP participant or who is affiliated with an entity on a Prohibited Entity List will require mitigation. Co-authorship on its own is a basis for mitigation, not for denial. The Prohibited Entity Lists are now a compilation of 13 U.S. Government restricted-party lists, up from 4. Foreign Country of Concern (FCOC) funding and certain foreign or co-filed patent activity can trigger the same review. The Army Research Laboratory applies its own Army Research Risk Assessment Protection Program (ARRP), under which co-authorship or conference-panel participation with a “strategic competitor” (as identified in the Director of National Intelligence Annual Threat Assessment, which includes China, Russia, Iran, and North Korea) is a distinct risk factor in its own right, independent of whether the co-author appears on a prohibited list.
NSF	PIs and co-PIs on active awards must certify annually, through Research.gov, that they are not participating in an MFTRP. Anyone currently party to an MFTRP is ineligible to serve as senior or key personnel, and all senior/key personnel must complete research security training within the 12 months before proposal submission. NSF’s TRUST framework and Important Notice No. 149 (effective December 2, 2025) set out the broader requirements, and institutions that maintain a Confucius Institute agreement are ineligible for NSF funding absent a waiver. In a July 8, 2026 Dear Colleague Letter, “Prohibition on Collaborations with Restricted Entities,” NSF announced a forthcoming policy — planned for Fiscal Year 2027 — that will bar NSF funds from supporting collaborations with any entity on a U.S. restricted-party list and will prohibit senior/key personnel from holding an appointment or position with, receiving support from, or collaborating with those entities for the duration of an award.
NIH	NIH takes a broad view of what counts as a foreign component: a collaboration with a researcher at a foreign site that is expected to result in co-authorship is a foreign component requiring NIH prior approval, even where the arrangement is informal or was never put in writing. If foreign co-authorship is anticipated, submit a pre-approval request through the Office of Sponsored Programs before the collaboration starts. Current MFTRP participants may not serve as senior or key personnel. Under NOT-OD-25-155 (and NOT-OD-25-104), NIH no longer funds foreign collaborators through traditional subawards or consortia; instead, each foreign collaborator is funded through a separate “International Project” component (PF5/UF5 activity codes). Sharing data or biospecimens from U.S. persons with a country of concern is restricted.
DOE	DOE has restricted talent-program participation longer than most agencies, under DOE Order 486.1 (2019). Anyone currently participating in an MFTRP may not take part in a DOE-funded project, and PIs and key personnel certify their status through the SciENcv Common Forms as part of the proposal. If a research team learns after the fact that someone is, or may be, part of an MFTRP, DOE must be notified within five business days. DOE screens collaborators against restricted-party lists, but it does not treat co-authorship with someone from a country of concern as a separate, standalone risk factor the way the DoD matrix and ARL do.
USDA	USDA’s Secretary’s Memorandum SM 1078-014 (July 8, 2025), the “America First Memorandum for USDA Arrangements and Research Security,” is broader than most agencies’ policies. For USDA extramural award recipients, the memorandum requires Common Forms disclosures, annual certification that the recipient is not party to a malignFTRP, and annual research-security-training certification. The employing institution must, among other things, bar anyone who participated in a malign FTRP within the past 10 years from working on the award. SM 1078-014 states that it is not a final agency action and creates no enforceable rights, but noncompliance may result in suspension or termination of USDA funding.
NASA	Since 2011, federal law — the Wolf Amendment, carried forward in successive appropriations acts and most recently in Section 526 of the Consolidated Appropriations Act, 2026 (P.L. 119-74) — has barred NASA from using its funds for any bilateral work with China or a Chinese-owned company, including Chinese universities. The restriction follows the funding and the institutional affiliation, not the researcher’s nationality or citizenship, so it reaches anyone with a qualifying Chinese government or company tie regardless of their home or current country of residence. This extends to publications: a paper co-authored only with a China-affiliated researcher generally cannot draw on NASA funds, even to cover page charges, though a separate non-NASA award covering the same work would be unaffected. Multilateral activity is generally permitted — but “multilateral” means the involvement of a third country (or a multilateral organization), not simply adding another U.S. party to a U.S.–China collaboration. NASA also requires senior and key personnel to certify that they are not participating in an MFTRP, consistent with the CHIPS and Science Act.

Should I list my federal grant number on all publications?   

Acknowledge federal funding on all publications describing the funded work, as required. However, attributing a paper to an award that did not support the described work runs counter to federal policy and can invite scrutiny. Apply a simple two-part test: cite an award only when the work arises directly from it and falls within its scope. If a foreign collaboration is unrelated to the award, do not cite that federal award number on the resulting publication.

I think I’ve been approached by a Foreign Talent Recruitment Program. What do I need to know?   

The White House Office of Science and Technology Policy (OSTP) defines a Foreign Talent Recruitment Program (FTRP) as any program, position, or activity that provides compensation — directly or indirectly — from a foreign country, or from an entity based in, funded by, or affiliated with one. Compensation can take the form of cash, in-kind support, research funding, complimentary travel, honorific titles, career-advancement opportunities, or other consideration.

Not every FTRP is malign. An FTRP is a Malign Foreign Talent Recruitment Program (MFTRP) only when it meets both of the following:

(1) A problematic condition — in exchange for the compensation, the program requires you to do one or more of the following:

Transfer intellectual property, materials, data, or other nonpublic information without authorization, or recruit other trainees or researchers into the program; Establish a foreign lab, company, or faculty appointment that conflicts with your U.S. award’s terms, or accept terms that bar you from ending the agreement except in extraordinary circumstances; Limit your ability to carry out a federally funded award, duplicate that work, or apply for the foreign sponsor’s funding with the foreign entity as the recipient; Omit acknowledgment of Pitt or the funding agency, leave the program off required disclosures, or maintain an undisclosed conflict of interest or commitment.

 

Under the CHIPS and Science Act, a covered individual may not participate in an MFTRP while applying for or working on a federally funded R&D award.

Participation in any FTRP — malign or not — must be disclosed both through Pitt’s MyDisclosures process and to your federal sponsor, typically on the Current and Pending (Other) Support and Biographical Sketch forms. A malign program is prohibited; a non-malign one is permitted but still must be disclosed.

Standard international activities are not FTRPs, so long as they are not funded, organized, or managed by an academic institution or program on the Section 1286 list. These include publishing and presenting research, attending international conferences and open scientific exchanges, participating in professional societies, mentoring foreign students, Fulbright programs, sabbaticals and visiting-scholar positions, and receiving prestigious research honors such as the Nobel Prize.

If you think you’ve been contacted by, or are already associated with, an FTRP or MFTRP, email researchsecurity@pitt.edu before making any commitments. It is always better to ask first.

(2) Problematic sponsorship — the program is sponsored by, based in, or affiliated with:

A foreign country of concern (China, Russia, Iran, or North Korea) or an entity based there; or An academic institution or a foreign talent recruitment program on the NDAA Section 1286 list, which satisfies this element regardless of the funding source. (Programs that themselves appear on the Section 1286 list have already been identified by the government as malign.)

What do I need to know before sharing materials or data with a foreign colleague?   

Before you share anything with a foreign collaborator, settle two questions for each item — whether a data set, software, biological sample, or piece of equipment: who owns it, and what use conditions apply (restrictions on how it may be used, shared onward, or published). The Office of Sponsored Programs (OSP) and the Innovation Institute can both help you work this out.

Once ownership and use conditions are settled, the appropriate agreement must be signed between Pitt and the collaborating institution before any work begins or any item is transferred. Depending on the situation, that may be a Material Transfer Agreement (MTA), Data Use Agreement (DUA), Confidential Disclosure Agreement (CDA), Non-Disclosure Agreement (NDA), subcontract, or research collaboration agreement. OSP can help you determine which one fits.

Finally, some data and materials cannot be shared with certain institutions or individuals at all:

The Department of Justice (DOJ) Data Security Rule prohibits or restricts transfers of bulk U.S. sensitive personal data and U.S. government-related data to a country of concern, or to a “covered person” affiliated with one. Under NIH’s Policy on Enhancing Security Measures for Human Biospecimens (NOT-OD-25-160, effective October 24, 2025), human biospecimens from U.S. persons that were collected, obtained, stored, used, or distributed with NIH funds may not be shared with institutions or parties in a country of concern. There is no minimum quantity — even a single biospecimen is covered, regardless of whether it is identifiable.

 

For both the DOJ and NIH restrictions, “countries of concern” means China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and Venezuela.

• Sanctions on certain countries, such as Iran, may require a license from the Treasury Department’s Office of Foreign Assets Control (OFAC) before any data is shared.

Should I be concerned with export controls if I want to hand-carry something out of the country?   

Yes. U.S. export control regulations apply to all items shipped or hand-carried out of the country. Some items — such as biological or chemical samples, lasers, or munitions — commonly need an export license before they leave the country. Even when an export license isn’t required, items still need to be declared to Customs and Border Protection. Ship through ProShip, or contact ORSTC (researchsecurity@pitt.edu) for a review of hand-carried items before you travel.

What common-sense steps should I take before traveling internationally?   

Before traveling, know where you’re going (embargoed or sanctioned countries need advance review), what you’re taking (inventory your items and determine whether export licenses are required), and with whom you are meeting (screen collaborators against restricted-party lists). Additional practical tips: pre-register your travel with Pitt Global Operations, take a loaner laptop, and use a VPN when accessing Pitt resources from foreign locations. Additional travel-security advice is available on the Global Operations website and through the Office of Research Security and Trade Compliance.

What are recent policies related to international engagement?   

Several recent policies restrict certain research transactions with foreign countries and govern how federal funds may be used:

• DOJ Data Security Program: Issued by the U.S. Department of Justice and effective April 8, 2025, this rule restricts transfers of bulk U.S. sensitive data (even when de-identified) to China (including Hong Kong and Macau), Russia, Iran, North Korea, Cuba, and Venezuela; permissible record counts vary by data type.
• NIH Human Biospecimens Policy (NOT-OD-25-160): Effective October 24, 2025, entities holding NIH-supported U.S.-person biospecimens may not directly or indirectly distribute them to institutions or parties in countries of concern (China, Cuba, Iran, North Korea, Russia, Venezuela) absent a narrow, documented exception.
• Restricted-party lists / Section 1260H: DoD updated its Section 1260H list of Chinese military companies on June 8, 2026, newly naming biotechnology firms including WuXi AppTec and Novogene and expanding BGI Group’s listed affiliates. Under Section 805 of the National Defense Authorization Act (NDAA) for FY2024, effective June 30, 2026, DoD/DoW may not enter into, renew, or extend contracts to procure goods, services, or technology from these entities.

This is a lot — how do I stay compliant?  

Federal requirements are evolving quickly, and the University will keep you informed through the Office of Research Protections (ORP) newsletter, webinars, and seminars. You may also contact the Office of Research Security and Trade Compliance at any time for guidance. Many University offices track these restrictions and maintain systems to help prevent transactions that could violate them.