Recommend that you treat a foreign recipient with no experience with NIH as
fully unknowledgable.  Be explicit about applicable regulations, and
provide URL's.  Also inform them as to what does not apply; you need to
know that anyway to ensure proper monitoring of them.  You will have to add
some clauses to your agreement to handle special matters.  The NIH GPM is a
start place, but give them CFR's and OMB Circulars, too.  And specify that
"requests to the sponsor agency" come to you, not NIH.

 From experience, I also recommend that you include a clause warranting
that the individual who sign the agreement has the authority to execute on
behalf of the institution.

Chuck

At 01:34 PM 3/5/2003 -0600, you wrote:
>A foreign subcontractor wants to say that it will comply only with  those
>"federal laws provided to it by us"!  If a foreign entity applies as a
>subcontractor, shouldn't it be responsible for knowing which regulations
>apply to it?
>
>Should we just refer them to the "dot gov" web site and tell them all the
>regs they need are on there?!
>
>Since it's an NIH sub, is the NIH Grants Policy Manual comprehensive enough?
>
>You may reply directly to me at xxxxxx@utmem.edu
>
>Thanks!
>
>Debbie Smith
>
>Deborah (Debbie) L. Smith, Ed.D.
>Director, Research Administration
>UT Health Science Center
>8 So. Dunlap, Suite C-109
>Memphis, TN  38163
>(901) 448-4823
>(901) 448-7600 fax
>xxxxxx@utmem.edu
>
>
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Herbert B. Chermside, CRA
Director, Sponsored Programs Administration
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Express Delivery Only:
 Biotech One, Suite 113
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 Richmond, VA 23219
Voice:  804-828-6772
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Personal e-mail xxxxxx@vcu.edu
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