Hi Debbie,

Maybe I'm being too simplistic here, but I pulled out my copy of A-110 and the Copeland "Anti-Kickback" Act seems to apply to construction awards.  I then took a quick peek at the PHS 398 application kit's checklist page, and there's no mention of it there.  To hit the trifecta, I went to the SF-424B, Assurances for Non-Construction Programs, and didn't see the Copeland Act mentioned.

So if you're dealing with a non-construction project, I think you're okay.

Hope this helps.

Pat

Patricia A. Hawk
Assistant Director, Sponsored Projects Administration
Oregon Health and Science University
Mail Code AD220
2525 SW First Ave.,Suite 220
Portland, OR  97201
Voice:  503-494-3211
Fax:  503-494-1191
e-mail:  xxxxxx@ohsu.edu

>>> xxxxxx@UTMEM.EDU 10/01/03 03:07PM >>>
Can anyone tell me quickly whether the anti-kickback regs are applicable to
foreign subs under NIH grants? I didn't find it in the reference table in
the NIH Policy Statement.

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

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