A Law360 article analyzes updated grants policy guidance from the National Institutes of Health requiring that each primary awardee institution impose on foreign entity subawardees an obligation to provide to the prime awardee all relevant research records, including data and lab notebooks.
The authors note the updated NIH policy guidance may be viewed as limiting the ability of foreign entities to misuse or divert federal research funds. The article explains that if the policy guidance is enacted in its current form, prime grant awardees will need to take steps to ensure compliance with this heightened responsibility, including modifying their contracts with foreign subrecipients and increased monitoring of those subawarees.
The article was authored by health care counsel Steve Sencer and Leslie Thornton and health care associate Minal Caron with contributions from health care partner Mark Barnes and health care associate Caroline Himamshu.
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