NIH worked with program offices to develop definitions of functions
in accordance with the requirements of the FAIR Act which requires the
inventory. ICs then placed their employees in the appropriate function.
Many agencies, including other DHHS operations divisions, have inventories
of commercial activities greater than NIH. We are currently reviewing our inventory to ensure that it accurately reflects the nature of the positions listed, and have already identified functions, such as Fire Protection Services, that we will ask the Department to move from the commercial competitive category.
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