Re: Foreign Sub Luc Simon 06 Mar 2003 09:57 EST
Of course a foreign entity that applies as a subcontractor should be responsible for knowing which regulations COULD be applied to it ! Technically, the subcontractor might have already filed an assurance with OHRP if the research involves human subjects. Other than that, the obligations should be specified in the subcontract because by default, a foreign entity has to abide by the applicable local law, and then only to whatever agreed to contractually. I have been involved in a number of subcontract agreements, and I did learn a lot during fruitful discussions with research managers from various US institutions. As colleagues, we appreciate that our role is to make sure that we can cooperate as effectively on the "administrative issues" as researchers from our respective institutions collaborate on the "scientific issues". If only as a courtesy, it would indeed be nice if administrators from the foreign entity were provided with a comprehensible subcontract that clearly states what is expected in term of reports, disclosures, assurances, etc... As mentioned bu Chuck, an honest look at what does not apply to foreign entities is well worthwhile. As with many things in life, the first time around is quite something, and with experience comes confidence ! Regards, Luc Simon Le 05/03/03 14:58, « Herbert B. Chermside » <xxxxxx@VCU.EDU> a écrit : > 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 >> >> >> ====================================================================== >> Instructions on how to use the RESADM-L Mailing List, including >> subscription information and a web-searchable archive, are available >> via our web site at http://www.hrinet.org (click on "Listserv Lists") >> ====================================================================== > > 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 > Virginia Biotechnology Research Park > 800 East Leigh Street > Richmond, VA 23219 > Voice: 804-828-6772 > Fax 804-828-2521 > OFFICE e-mail xxxxxx@VCU.EDU > Personal e-mail xxxxxx@vcu.edu > http://www.research.vcu.edu/ospa.htm > > > ====================================================================== > Instructions on how to use the RESADM-L Mailing List, including > subscription information and a web-searchable archive, are available > via our web site at http://www.hrinet.org (click on "Listserv Lists") > ====================================================================== > ========= Luc Simon Conseiller en gestion de la recherche Vice-rectorat a la recherche Université Laval Telephone: (418) 656-2131 - poste 5301 Telecopieur: (418) 656-2506 Email: xxxxxx@vrr.ulaval.ca ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================