Ms. Ford,

I work within a university education institute framework and, therefore, I can not claim expert knowledge in this area.

1) However, OMB A-87 (below) mandates that "schools districts" fall within the definition of "local government". Please note that, in contrast, A-21 (section A1) application is limited to "colleges and universities".
Circular No. A-87
Attachment A
B. Definitions
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.
http://www.whitehouse.gov/omb/circulars/a087/a087a.html

2) Confusion about OMB Circular applicability may derive from situations in which university grants funded by the federal government also Subcontract to a public school/district. However, OMB clearly mandates A-87 applicability in such cases (see below).
A. Purpose and Scope
3. Application.
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.
http://www.whitehouse.gov/omb/circulars/a087/a087a.html

I hope that my response is of some benefit.

Regards,
Steve

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On 5/20/02, Angela Ford 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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