Why did the OIG conduct this audit
The OIG commissioned this audit because of concerns regarding grant awards to the National Institutes of Health’s (NIH) EcoHealth Alliance (EcoHealth), NIH’s oversight of EcoHealth, and EcoHealth’s use of grant funds, including subcontracting to a foreign entity. – Includes monitoring of rewards.
Our objectives were to determine whether: (1) NIH monitored grants to EcoHealth in accordance with federal requirements and (2) EcoHealth used and managed its NIH grant funds in accordance with federal requirements.
How did the OIG conduct this audit
We obtained a list of all NIH awards to EcoHealth and all subawards awarded by EcoHealth during the federal fiscal years 2014 to 2021 (the audit period). Our audit included three NIH awards totaling approximately $8.0 million to EcoHealth, including $1.8 million of sub-awards to EcoHealth from eight sub-recipients, including the Wuhan Institute of Virology (WIV).
Our audit methodology was designed to monitor NIH and EcoHealth’s policies, procedures, and internal controls for managing and using grant funds. We selected and reviewed 150 EcoHealth transactions totaling $2,578,567 across 3 NIH awards with a variety of cost categories for acceptability.
what oig found
Despite identifying potential risks associated with research being conducted under EcoHealth awards, we found that NIH did not effectively monitor or take timely action to address EcoHealth’s compliance with certain requirements. Although NIH and EcoHealth had established monitoring procedures, we found deficiencies in compliance with those procedures that required NIH and EcoHealth to effectively monitor federal grant awards and understand the nature of research conducted, identify potential problem areas and Limits the ability to take corrective action. Using its discretion, NIH did not refer the research for enhanced potential pandemic pathogens (ePPPs) to HHS for external review after it determined that the research was not involved in creating, using, or transferring the ePPPs. was not reasonably anticipated. However, the NIH added a special term and condition to EcoHealth’s awards and provided limited guidance on how EcoHealth should comply with that requirement. We found that NIH was only able to conclude that the research resulted in the development of a virus that met specified benchmarks based on EcoHealth’s late progress report that NIH failed to comply with nearly 2 years after its due date Stayed. Based on these findings, we conclude that NIH missed opportunities to more effectively oversee research. With better oversight, NIH may be able to take more timely corrective action to reduce the inherent risks associated with this type of research.
We identified several other deficiencies in the oversight of the awards. Some of these shortcomings include: improper termination of grants by NIH; EcoHealth’s inability to obtain scientific documentation from WIV; and improper use of grant funds by EcoHealth, which resulted in an unacceptable cost of $89,171.
OIG oversight work has consistently demonstrated that grant-giving agencies’ oversight of subrecipients, whether domestic or foreign, is challenging. The deficiencies we identified related to NIH’s oversight of EcoHealth demonstrate continuing problems. Adding to these long-standing challenges are risks that may limit effective oversight of foreign subrecipients, which often depend on cooperation between recipient and subrecipient, and countries in which research is conducted. . Although the WIV cooperated with EcoHealth in monitoring for several years, the WIV’s lack of cooperation after the COVID 19 outbreak limited EcoHealth’s ability to monitor its subcontractors. NIH should assess how it can mitigate these issues and ensure that it can oversee the use of NIH funds by foreign recipients and subrecipients.
What the OIG Recommends, and Comments from the National Institutes of Health and EcoHealth
We recommend that NIH ensure that EcoHealth reports award and subaward information in an accurate and timely manner; Ensure that administrative action is taken appropriately; implementing enhanced monitoring, documentation and reporting requirements for recipients with foreign subrecipients; Evaluate whether NIAID staff are following policy to err on the side of inclusion when determining whether to refer research that may include EPPP for further review; Consider whether it is appropriate to refer the WIV to HHS for exclusion; ensuring future NIH grant awards to EcoHealth address the deficiencies noted in the report; and reconcile the costs identified as possibly unreimbursed costs together with the allowed costs.
In written comments, NIH stated that it agrees or generally agrees with our recommendations, and provided actions taken or planned to address them, which are more fully described in the report.
We recommend that EcoHealth submit progress reports by the required due date, comply with immediate notification requirements, ensure access to all subrecipient records, properly account for subwards, and return $89,171 in unaccounted costs to the federal government. Do it
In written comments, EcoHealth agreed with our recommendation to prepare accurate subwards and advisory agreements but did not directly state whether it agreed with other recommendations. EcoHealth identified two basic areas of disagreement with the reported findings: (1) the timeliness of EcoHealth’s Year 5 progress report and (2) whether an experiment demonstrated evolution of the virus. With respect to the nine monetary recommendations, EcoHealth stated that it reimbursed NIH for the total reported unreimbursed costs and provided details of the amounts of allowable but unreimbursed costs to NIH. However, EcoHealth disagreed with the OIG’s interpretation of federal requirements for certain items of cost.
With respect to EcoHealth’s comments regarding the timeliness of EcoHealth’s Year 5 progress report, we have no evidence that the progress report introduced on NIH’s online portal in July 2019 was fully implemented on the online portal at that time. was uploaded from With respect to the finding that one experiment demonstrated “enhanced growth,” our audit did not assess the scientific results for either experiment or the accuracy of NIH or EcoHealth’s interpretation of the Year 4 and 5 research results. No determination made. Our audit found that its evaluation of NIH’s Year 5 progress report concluded that the research was of a type that should have been reported to NIH immediately.
Filed Under: National Institutes of Health