Background
International collaboration is a cornerstone of modern research and is typically encouraged by U.S. federal agencies. At the same time, federal sponsors often scrutinize global engagements to protect federally funded research from influence by foreign governments and to ensure oversight of federal funds.
Notably, co-authored research publications can trigger scrutiny by federal agencies, even when no meaningful collaboration, funding relationship, or research overlap exists. Inconsistencies between publications and disclosures to sponsors (or misinterpretation of publication data) may prompt additional review by federal funding agencies.
What Researchers Should Do
Full transparency and proactive compliance are the best ways for Lehigh researchers to minimize risk when collaborating with or co-authoring research papers with partners outside the United States. Researchers should take the following steps:
- Ensure complete and accurate disclosures. Maintain up-to-date disclosures with sponsors, including listing new relationships in progress reports. Include all affiliations and all support, including in-kind support or shared materials.
- Be aware of how publications are interpreted. Co-authorship may be treated as evidence of collaboration and/or evidence of a foreign component. For example, a publication with a foreign co-author may be interpreted as having required a federal agency’s prior approval, even when the collaboration was limited or indirect.
- Exercise due diligence regarding collaborations. List only true collaborators as co-authors. If you are working with a collaborator who was not screened at the time of a proposal submission, work with the Office of Research Integrity to screen co-authors (institutions and individuals) against U.S. government restricted party lists prior to publication.
- Understand the risks of collaborations over your career. Be aware that all collaborations — whether federally funded or not, or whether formal or informal — can result in co-authored publications, triggering compliance scrutiny now or in the future. Researchers engaging in informal collaborations should request a restricted party screening from the Office of Research Integrity.
- Seek guidance when in doubt. Contact the Office of Research Integrity or your Contract and Grant Specialist with any questions. In certain circumstances, coauthoring publications with overseas collaborators may require prior sponsor approval (see NIH section below).
Sponsor-specific Disclosure Requirements
All federal sponsors require researchers to disclose all current and pending support, including domestic and foreign contracts, grants, awards, and in-kind support. In addition, sponsors may have specific disclosure requirements based on U.S. law or agency policy.
SPONSOR | REQUIREMENTS |
National Institutes of Health (NIH) | In May 2026, the NIH clarified that collaborations anticipated to result in co-authorship with investigators at a foreign site are considered a "foreign component” that requires prior NIH authorization. NIH goes on to state that “most instances of co-authorship represent a foreign component.” Based on current NIH guidance, NIH-funded researchers should report potential collaborators or co-authors to the NIH to determine what, if any, steps need to be taken. Researchers may work with their ORPA Grant and Contract Administrator to report the engagement to the NIH. On June 11, 2026, Michelle G. Bulls, Director, NIH Office of Policy for Extramural Research Administration (OPERA), presented this presentation to the Council of Government Relations. The presentation clarifies NIH policies regarding “foreign components” in NIH-funded research, particularly in the context of international co-authorship and collaboration. It also offers several case studies illustrating what is and is not considered a foreign component. In September 2026, as part of the FDP Research Security Subcommittee on Co-authorship and Foreign Components, NIH Extramural Leadership provided answers to FAQs regarding foreign collaborations and engagement with restricted entities, including sample scenarios. |
National Aeronautics and Space Administration (NASA) | Since 2011, Public Law 118-42 Section 526 has prohibited use of NASA funds for bilateral activity with China or Chinese entities. (Note that the statute does not restrict participation in NASA-funded projects by Chinese nationals affiliated with U.S. institutions. See NASA FAQ for additional information.) For example, papers that include authors only from the U.S. and China may not use NASA funds to support publication of the paper. However, the restriction applies only to NASA funds; a researcher with both NASA and NSF funding who is conducting NSF-funded research with parties in China would not be prohibited from doing so, as long as the NASA and NSF projects are separate. |
Department of Defense (DOD) / DOW | The March 2026 update to the Department’s "Decision Matrix" acknowledges that international collaboration provides benefits to fundamental research activities, while also stating that co-authorship is “useful in providing a full picture of a fundamental research project’s risks.”
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Department of Energy (DOE) | Like DOD, DOE evaluates ties to foreign entities or foreign collaborators on restricted party lists, but does not otherwise consider co-authorship with parties in a foreign country of concern (currently China, Iran, Russia and North Korea) as a risk factor. Transparency of relationships involving foreign countries of concern, restricted entities, foreign funding and foreign talent recruitment programs is expected. |
National Science Foundation (NSF) | NSF recently announced an upcoming policy that will prohibit the use of NSF funds to conduct research activities in collaboration with restricted entities or their employees. In addition, senior/key personnel on NSF projects may not hold an appointment or position with, or receive research support from, restricted entities. |
FAQs
Based on the most recent guidance from federal funding agencies, affiliations listed on papers should reflect the institution where the work was performed. For example, if the work was performed at Lehigh, the affiliation should be listed as Lehigh. (The current contact information for the individual can reflect their current institution.)
Federal funding agencies will require that additional collaborative activities with individuals affiliated with a restricted party be ended.
Significant participation by a foreign entity in an NIH-funded research project is considered a Foreign Component. Such collaborations require prior authorization from the NIH.
It is important to clearly and accurately describe the role of contributors. If certain individuals contributed code via the repository, but did not otherwise collaborate on the sponsored project, make it clear in the acknowledgements section that they contributed code while noting that they were not part of the sponsored project.
Additional Resources
The Council on Government Relations is an association of leading research universities and affiliated medical centers and independent research institutes. COGR prepared an issue brief related to international collaboration and research security risk assessments conducted by federal funding agencies - including a shift in focus from the research itself to the researchers, their affiliations, and relationships. The issue brief is available here.
NIH
Definition of Foreign Components (May 2026)
Acknowledging Foreign Components throughout NIH Application and Award Processes (June 2026)
Foreign Component Discussion COGR (June 2026)
FAQs - FDP Research Security Subcommittee Co-authorship and Foreign Components (September 2026)
NSF
Prohibition on Collaborations with Restricted Entities (July 2026)
NASA
Certification of Compliance with Applicable Executive Orders and U.S. Code (NSPIRES)
DOW / DOD