OIG Audits and Compliance Issues To Watch

A fabulous presentation that everyone missed at the end of the day was on the Office of Inspector General’s Workplan and how to pinpoint new compliance areas to keep in mind.

A key difference in the NSF and NIH OIG offices – NSF audits are outsourced. NIH audits are not, so reviewing the OIG work plan for NIH is a good guide.

Some interesting items on the agenda for the coming year:

1. Clinical and Translational Science Awards – there are rules that allow for direct charging of items that are unusual for NIH, and these awards are large. Also, there is a concern about the monitoring of sub awards.
2. Recharge centers-everything is up for grabs, they haven’t audited recharge centers in 15 years.
3. Informed consent and privacy protections in genetic research.
4. Extra service compensation payments made by educational institutions (effort on grants at multiple universities, summer and supplemental pay).
5. All ARRA awards will be reviewed.

Monitoring sub-awards is a hot area that encompasses many of these issues in and of itself, because the OIG is looking at the monitoring of awards AND how the sub is then compliant with NIH guidelines, such as effort reporting, because prime awardees are ultimately responsible for the conduct of their subs. Recent audits have been in this area and in the area of extra compensation that was charged to grants as a direct cost.

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