Angela-
OMB A-21 reads:
A. Purpose and scope.
1. Objectives. This Attachment provides principles for determining
the costs applicable to research and development, training, and other
sponsored work performed by colleges and universities under grants,
contracts, and other agreements with the Federal Government. These
agreements are referred to as sponsored agreements.
and also:
3. Application. These principles shall be used in determining the
allowable costs of work performed by colleges and universities under
sponsored agreements. The principles shall also be used in determining
the costs of work performed by such institutions under subgrants,
cost-reimbursement subcontracts, and other awards made to them under
sponsored agreements. They also shall be used as a guide in the pricing
of fixed-price contracts and subcontracts where costs are used in
determining the appropriate price. The principles do not apply to:
....
I think that OMB A-21 applies to educational institutions of higher
education. Local educational agencies, LEAs, use OMB Circular A-87,
Cost Principals for State, Local and Indian Tribal Governments, while
their sub-awardees may not. I cut and pasted the following
paragraphs from OMB A-87.
16. "Local government" means a county, municipality, city,
town, township, local public authority, school district, special
district, intrastate district, council of governments (whether or not
incorporated as a non-profit corporation under State law), any other
regional or interstate government entity, or any agency or
instrumentality of a local government.
3. Application.
a. These principles will be applied by all Federal agencies in
determining costs incurred by governmental units under Federal awards
(including subawards) except those with (1) publicly-financed educational
institutions subject to OMB Circular A-21, "Cost Principles for
Educational Institutions," and (2) programs administered by
publicly-owned hospitals and other providers of medical care that are
subject to requirements promulgated by the sponsoring Federal agencies.
However, this Circular does apply to all central service and
department/agency costs that are allocated or billed to those educational
institutions, hospitals, and other providers of medical care or services
by other State and local government departments and agencies.
b. All subawards are subject to those Federal cost principles applicable
to the particular organization concerned. Thus, if a subaward is to a
governmental unit (other than a college, university or hospital), this
Circular shall apply; if a subaward is to a commercial organization, the
cost principles applicable to commercial organizations shall apply; if a
subaward is to a college or university, Circular A-21 shall apply; if a
subaward is to a hospital, the cost principles used by the Federal
awarding agency for awards to hospitals shall apply, subject to the
provisions of subsection A.3.a. of this Attachment; if a subaward is to
some other non-profit organization, Circular A-122, "Cost Principles
for Non-Profit Organizations," shall apply.
I hope this helps. Mary Barbosa
At 09:51 AM 5/20/02 -0500, you wrote:
Hello,
I'm passing along a question from a colleague:
OMB Circular A21 applies to colleges and universities. Does it also
apply
to K-12 public schools, or school districts?
Thank you in advance for your help.
Angela Ford
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Mary Susan Barbosa, CRA
Grants Officer
Glendale Community College
1500 North Verdugo Road
Glendale, CA. 91208-2894
telephone: (818) 240-1000, Extension 5823
fax: (818) 549-9436
email: xxxxxx@glendale.edu