I believe A-21 should apply in all cases to an educational institution.  I
think the grants officer is in error.  One "kludge" solution might be
another award to a state agency or authority with a direct relationship to
your state university -- but that's the "long way 'round".

Chuck

At 02:35 PM 4/19/01 -0500, you wrote:
>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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