What is a primary awardee’s responsibility for sub-recipient compliance with the NIH Public Access Policy?
The primary awardee’s obligation to ensure sub-recipient compliance with the NIH Public Access Policy is the same as the awardee’s responsibility for other requirements when collaborating with other organizations in carrying out NIH-supported research. Accordingly, the NIH Public Access Policy requirement should be incorporated into sub-recipient agreements, and the primary awardee remains responsible for compliance.