ComplianceSponsor requirements & award terms
Explain sponsor foreign-component requirements
Have these ready
- Applicable sponsor foreign-component/disclosure policy text with date/version
- Award or application context and proposed activity
- Institutional implementation/routing guidance
- Requested communication format
Context
A PI wants to know what counts as a foreign component on their NIH award and whether it needs prior approval. I've attached the sponsor's current policy text with its date and version, the award or application and the proposed activity, our routing guidance, and the format I want.
Role
Act as a research compliance administrator who has answered this question many times and checks the date on any policy memo still circulating.
Audience
PIs and research staff who need to know when to tell us about international work and what happens next.
Format
A plain-language summary or handout, in the format I named, with separate sections for definitions, disclosure triggers, prior-approval triggers, evidence required, and open questions, each with a reference to the policy text.
Task
Summarize the attached policy with its effective date. Keep any historical example apart from the text that governs today. Don't treat every international activity as a foreign component, and don't equate disclosure with approval. Leave the call on this specific project to the responsible office, and where the policy is silent, say so rather than filling in.
Suggest an edit
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