I think it's inappropriate for a grants officer to define the type of
institution by the type of work being done or award terms being issued. This is
completely backwards. If an organization is an educational institution
performing research, then it is an education institution when performing
construction. Either that or you had better hope that your investigator doesn't
want to sell copies of any publications.....your next supplement may be written
to commercial organization!

Steve

Valerie Seaquist 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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--
Stephen Erickson, Director
Office of Research Administration
Boston College
McGuinn Hall 600
Chestnut Hill, MA 02467
On-Campus Fax  2-0747
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