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Allowability of Costs/Cost Considerations for Foreign Grantees

Allowability of Costs / Activities (section 7.9) from the NIH Grants Policy Statement provides a list of allowable costs for NIH grants in general (including domestic and foreign). A list of allowable costs for foreign grants (section 16.6) is provided but is not intended to be all-inclusive.

Other cost considerations for foreign grants:

  • U.S. Dollars: The application budget, requests for funds, and financial reports must be stated in U.S. dollars. Once an award is made, NIH generally will not compensate foreign grantees for currency exchange fluctuations through the issuance of supplemental awards. Cost increases for fluctuations in exchange rates are allowable costs subject to the availability of funding, as determined by the awarding IC.
  • Customs and Import Duties: Allowable under grants to domestic organizations when performance will take place entirely within the United States, its possessions, or its territories, or when foreign involvement in the project is incidental to the overall grant-supported project. Charges may include consular fees, customs surtaxes, value-added taxes, and other related charges.
  • Valued Added Tax (VAT): Foreign taxes charged for the purchase of goods or services that a non-Federal entity is legally required to pay in country is an allowable expense under Federal awards. Foreign tax refunds or applicable credits under Federal awards refer to receipts, or reduction of expenditures, which operate to offset or reduce expense items that are allocable to Federal awards as direct or indirect costs. To the extent that such credits accrued or received by the non-Federal entity relate to allowable cost, these costs must be credited to the NIH awarding IC either as costs or cash refunds. If the costs are credited back to the Federal award, the non-Federal entity may reduce the Federal share of costs by the amount of the foreign tax reimbursement, or where Federal award has not expired, use the foreign government tax refund for approved activities under the Federal award with prior approval of the NIH awarding IC. For many countries an exemption of this tax for research exists. Consequently, requesting this cost should be unallowable for research grants involving such countries as a performance site.
  • Visa Costs: Generally, allowable direct cost as part of recruiting costs on an NIH grant, as long as the institution has an employee/employer relationship with the individual. Visa costs may also be allowable when identified in specific FOAs or when within the scope of an approved research project. When included as a recruiting cost it is the responsibility of the institution to monitor the status of the individual's visa and ensure they have sufficient time to fulfill the obligations of the research they are being paid for on the grant. However, if the person is already an employee and the cost in question is a visa renewal then this isn't a recruiting cost so the cost would not be an allowable charge to a grant. Expedited processing fees are generally unallowable unless and until they become part of standard processing fees. Fraud prevention and detection fees are allowable if they are required fees. Department of Homeland Security SEVIS Form I-901 is a required fee and is allowable.

Updated February 2, 2023