| Love reading all the TDS comments about Americans are the new Nazis and Orange Man is bad. However, this article isn't very good: NIH has publish guidance: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-1... It seems like the intent here is to prevent "subawards" going to foreign linked entities where the USG can't track it. The NIH is introducing a new linked award system where the foreign entity receives their own independent grant number and that primary on the application must be a US entity. This introduces new activity codes (PF5 regular grant and UF5 cooperative agreement) where upon granting the new money the foreign entity will receive their own RF2 grant or UL2 grant (based on the original grant type). Under the old system a grant to a US institution (like a university) could be doled out to foreigner institutions as subawards without the USG seeing where the money was going. This is a violation of FFATA and the USG wants to track these dollars because US universities are not reporting it. Additionally the USG has grown increasing suspicious of certain countries (think russia, china) that are getting subawards that are effectively transferring US IP to these entities via pliant US individuals at an institution. This forces the PI to get a linked award and pull these folks out of the shadows where they are now identified and where the USG can run a background check on them. This also deals with university outsourcing where an institution can get a grant and then simply pass the money off (mostly entirely) to a foreign entity where the US university became essentially a shadow distribution vehicle. Under the new rules to do this the PI must show that but funnel funds to a foreign institution that institution must offer something not readily available in the US. Once a foreign funded entity has received money in this way and then violates policy, or breached security it falls on the university to police their grants (which mostly they can't do effectively). So the USG wants to cut out the middleman and for the foreign entity to become a direct recipient of the grant making them legal liable to the USG for all the terms and conditions. If you violate the grant the NIH can sanction them directly without going through the university. |