The NIH Requirement to Submit IT Acquisition Strategies states that all commercial purchases of information technology (IT) products and services must be covered by an approved Acquisition Strategy to comply with FITARA.
This strategy must be prepared with the appropriate NIH FITARA Clearance template in accordance with the Guidance for Completing a FITARA Clearance (some ICs/Programs must comply with ITAR and OAP requirements based on the value of their acquisition). A FITARA Clearance may be written to cover all of an IC's IT acquisitions or just individual program level acquisitions.