Good Afternoon,

I'm researching this situation within my own institution but would also like
to get some feed-back from y'all out there. I've never run across this one.

We have a NASA cooperative agreement which is issued under the "NASA Grant &
Cooperative Agreement Handbook." Our clauses/provisions fall under sections
A & B which are the sections pertaining to educational institutions. The
cost principles are OMB Circular A-21 as expected for an educational
institution.

We have just received a supplement to the cooperative agreement which is
providing funds for facility construction related to the original
agreement's research effort. For this part of the funding, the supplement
incorporates Section C which is for state & local governments. (The grants
officer said we were a state institution, therefore = "State.") Section C
requires adherence to the cost principles of OMB Circular A-87 -- for state
& local governments.

Our institutional cost policy and our Disclosure Statement reference our
adherence to OMB A-21 as does everything else related to our research
expenditure/accounting.

Can we accept an award made to us as two kinds of entities, educational
institution and state government, and requiring that we adhere to two
different cost principles? I don't want to be obstructive just because I
haven't seen this before but it is a pretty weird animal to me.

Thanks for your input.

Val Seaquist
The University of Alabama in Huntsville

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