Thanks Diana,
I was just wondering why Section 4712 is particularly specified in the FDP. I guess it’s because this section has a unique application to grants in the, “Notification of Employees,” requirement that other sections
applicable to subcontractors don’t have?
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Diana Key
Sent: Tuesday, May 29, 2018 5:35 AM
To: xxxxxx@lists.healthresearch.org
Subject: [SUSPICIOUS URL!]Re: [RESADM-L] compliance with the National Defense Authorization Act (NDAA)
Hi Doug,
41 USC 4712 was amended in August 2017, removing the words “Pilot program for enhancement” and inserting “Enhancement”. Paragraph (a)(1) makes this applicable to federal grants regardless of funding agency. Attached
is a copy FYI.
Diana
Diana L. Key
Director, Research Compliance Programs
Florida State University
2019 Westcott North | Tallahassee, FL 32306-1330
(850) 644-8648
www.research.fsu.edu/research-compliance
From: Research Administration List <xxxxxx@lists.healthresearch.org>
On Behalf Of dougm (Doug Mounce)
Sent: Friday, May 25, 2018 3:57 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] compliance with the National Defense Authorization Act (NDAA)
So, one of our officers took notice of the FDP template for cost-reimbursable subawards and the, “Program for Enhancement of Contractor Employee Protections (41 U.S.C 4712)” requirement. I checked the NIH reference which has the, “Requirement
for compliance with the National Defense Authorization Act (NDAA)”, but the term is, “beginning July 1, 2013 through January 1, 2017”.
It appears from the NIH Notice that this Program has expired, and it’s no longer a Pilot Program in any case. I checked with the NIH, and a Program Officer called me back – she said she would follow-up with more information, but I haven’t
heard more. The NDAA appears to be active, with the same protections and improvements, as far as I can tell, although I didn’t research exactly how the NDAA automatically applies this requirement to grants.
We just found it curious that the NIH requirement appears to have expired. What do you think?
Doug Mounce, Grants & Contracts Manager, 206-839-1787
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