NIH Monkeypox Smuggling Release — page 12

From: To: "Knox, Shamay (NIH/NIAID) [E]" @niaid.nih.gov> @niaid.nih.gov>, "Munster, Vincent .gov>, "Embry, Alan (NIH/NIAID) [E]" (@niaid.nih.gov>, "Degrace, Marciela (NIH/NIAID) [E]" @niaid.nih.gov>, @niaid.nih.gov>, "Grewe, Charles (NIW/NIAID) [E]" iaid.nih. ennedy, George (NIH/NIAID) [E]" <E on: ih.gov> Ce: "Menk, Kay (NIH/NIAID) [E]" <i @niaid.nih.gov> Subject: RE: omicron update Date: Thu, 02 Dec 2021 17:34:25 -0500 Importance: Normal Hi everyone, I'm adding Chuck Grewe (NIAID's Chief CO and OA Director) and George Kennedy (NIAID OA Policy Branch Chief). George's branch is going to look into this issue for us. This is a tricky situation because if we ship materials ourselves without the authority to do so, and outside of the federal policy, it only takes one shipment to go wrong for it to end up as a Washington Post moment or congressional inquiry, like so many other acquisition/grant issues lately. This is a minor acquisition but given the nature of what we ship it could be high risk to NIAID, particularly in this climate. The Authority for international shipments is similar to the authority for leasing space in that it rests with GSA, and can be delegated under certain conditions. GSA controls Technical Service Orders (TSO) Shipping. When the NIH OD DLS office receives a request for shipping, they provide a Government Bill of Lading to the GSA administration. Then GSA procures the shipping on our behalf. The exception that is referenced in the policy (that Kay noted) states that, the IC's are able to use other appropriate mechanisms to purchase, but only after a policy is written and approved they the Director of DLS, see below: Appendix A: Supplement to Manual Chapter 26101-42-F; Section E. 1.c. Delegated Authority to Procure Shipping Services The NIH Institutes/ Centers (IC) activities below are delegated specific authority to Report of shipping activities will be provided as required by the Director, DLS. Although RML is listed as a site that could receive an exception, it does not currently have an approved SOP and process on file with DLS (we checked to confirm). That's probably where the previous confusion occurred... that the location is listed and perhaps it was assumed an SOP was in place. In order for us to procure these services, RML should produce one and gain approval. We don't have experience with this, or know what the SOP should contain, or the proper procedures to ensure we stay on the legal side of it. We are awaiting more information from the DLS office, but will engage OA's policy branch in taking this effort on from here. Vincent, I'm unclear on your note below (I highlighted it in red). How do you plan to procure it?