Can someone explain to me when the conditional exemptions in A-87 3.e. and
A-21 A.3.d.  apply?   We are having a "discussion" with a state agency that
wants us to follow A-87 on three new awards.  We pitched a small fit and
they have agreed that on one of the awards they will state that we comply
with A-21.  For another one they are saying it really isn't a subaward and
we will have to follow A-87.  For the third, the jury is still out.  Giving
them the benefit of the doubt that life might contain more kinds of
relationships than the traditional prime and sub I started reading to
figure out where they may have gotten such an idea.

A couple of years ago, we had a discussion with a person from USDA about
time sheets and other yucky things and she pointed out that on an
administrative grant she can deviate from A-21.  I am wondering if this is
something similar.  The comfort (if you can call it that) of knowing A-21
is on shaky ground today and I am confused - which won't help my
negotiations much.  Any info, advice, commiseration, guidance is appreciated.

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