Hello;

We have divergent views about whether, as an institution of higher education and the applicant on a DOE proposal that's being negotiated for an award, we are exempt from the requirement to provide information on foreign nationals.  For this award, we have subrecipients who are a mix of other IHEs, industry, and non-profit entities.  DOE seems to have two statements about this.

One DOE statement is:  All applicants, except institutions of higher education, selected for an award under this FOA may be required to provide information to the Department of Energy (DOE) in order to satisfy requirements for foreign nationals’ access to DOE sites, information, technologies, equipment, programs, and personnel. Provide the following information for each FN at the prime, subrecipient, or partner organization who is specifically named as either key personnel, lead researcher, principal investigator, or similar position, and is located in the U.S.

The other DOE statement is: Recipients (including subrecipients and contractors) that are institutions of higher education are exempt from obtaining DOE approval for FN access to DOE information provided that:  (1) the FN is an employee, student, or other individual with a direct affiliation with the institution of higher education; (2) the institution of higher education is performing research under the award; (3) the award is sponsored by a DOE program office that reports to the Under Secretary for Science and Energy; and (4) the institution of higher education intends to publish the results of its research for access by the general public.

My question-- Would only those subrecipients and contractors who are NOT institutions of higher education be required to provide the DOE-requested FN information?  OR Would none be required to do so as our institution is the applicant (See first part of first DOE statement).

I've thought myself into a pretzel on this! :-)

I look forward to hearing from the group.

____
Mark Lynam (xxxxxx@tntech.edu)

############################

To unsubscribe from the RESADM-L list:
write to: mailto:xxxxxx@LISTS.HEALTHRESEARCH.ORG
or click the following link:
http://lists.healthresearch.org/scripts/wa-HLTHRES.exe?SUBED1=RESADM-L&A=1