Hi, Mark--

Given the way the wind's been blowing lately, I suspect the answer is likely
to be (C) You'll be required to provide information about foreign nationals
at your subrecipient/partner organizations. But I'd absolutely ask the
cognizant program officer or grants specialist at DOE. (And they may not
know the answers either, given that policies seem to be in flux.)

Best regards,

Michael Spires, M.A., M.S., CRA
(He/him/his)
Research Development Officer, Sciences
The Research Office
Oakland University
256 Hannah Hall
244 Meadow Brook Road
Rochester, MI 48309-4451
(248) 370-2207
xxxxxx@oakland.edu
Past President, National Organization of Research Development Professionals
-----Original Message-----
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On
Behalf Of Mark Lynam
Sent: Wednesday, August 21, 2019 17:13
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] Foreign Nationals | DOE-NETL Award

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)

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