War story is right!

This A-21 rule may be more applicable to a cooperative agreement that I was involved with.  It involves one base award + multiple capitation awards for one multi-center grant and will have multiple projects/studies, under the direction and limits set by NIH.  In reference to the capitation awards, one study may have "more funding and/or expensed less" (in form of earned-excess capitation) than NIH allocated and those said "funds" may be used to cover the "less funded" studies.  Some studies will be capitated for several years and conversely reconciled after several years while other studies are capitated and capitated yearly.  There are some other  serious practical issues.

It is not a pretty sight to combine general capitation practices with federal rules and regulations.

J. Felix Gadi
713-500-9365 phone
713-500-9364 fax

-----Original Message-----
From: Ruth B Smith [mailto:xxxxxx@ODU.EDU]
Sent: Thursday, October 17, 2002 8:50 AM
To: xxxxxx@HRINET.ORG
Subject: Re: [RESADM-L] Reporting of interdisciplinary awards

Dear Colleagues,
An interesting policy consideration has reared its head.   I hope you can
offer advice or helpful war stories.
Under A-21 paragraph C.4.d (3), costs may be allocated among interrelated
projects supported by multiple federal awards without prior approval or
prior stipulation of relatedness.  How do you apply this in practice?
Presumably since the federal regulations do not set limits, institutions
probably do.  So, my bottom line question is what restrictions does your
institution place on such expenditure allocations and what, if any,
problems result.
Thank you for any guidance you can offer.

Ruth Smith
Executive Director
Old Dominion University Research Foundation
Ph 757-683-4293, ext. 600
Fax 757-683-5290
Mobile Ph 757-469-5675

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 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
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