No. It is the function of the Project Officer that is IG, not the individual.
NIH is restricted from outsourcing the oversight of government contracts
(IG functions). However, the individual generally has assignments that
are made up from both IG and commercial functions. NIH has the authority
to restructure the functions that make up an individual’s assignments
to meet the mission regardless of whether they are commercial or IG. Just
because an individual has been designated as IG for the FAIR Act inventory
because the preponderance of their duties are currently considered IG,
does not mean the function is exempt from review and restructuring. It
is entirely possible that a given individual’s responsibilities,
both IG and commercial could be reorganized to support a more efficient
and effective structure. |