https://oig.hhs.gov/reports-and-publications/workplan/summary/wp-summary-0000592.asp

OIG has previously identified NIH's oversight of grants to foreign applicants as a potential risk to the Department meeting program goals and the appropriate use of Federal funds. NIH must manage and administer Federal awards to ensure that Federal funding is expended and associated programs are implemented in full accordance with statutory and public policy requirements. To do so, NIH must monitor grantee performance and grantee use of NIH funds. Grantees are responsible for complying with all requirements of the Federal award, including maintaining effective internal controls over the Federal award (45 CFR § 75.300 and § 75.305).

Grantees that function as pass-through entities must monitor the activities of subrecipients, including foreign subrecipients, to ensure that subawards are used for authorized purposes in compliance with relevant laws and the terms and conditions of the subaward (45 CFR § 75.352). We will review NIH's monitoring of selected grants, and grantee use and management of NIH grant funds in accordance with Federal requirements.