The exception in A-21 you referred to is very unusual, and there will be
OMB documentation of it at least in the hands of the state.

Otherwise, A-21 must be used for all subawards.

Now there are times that the state PROCURES services that the University
may be expert in providing.  (Really a procurement!!)  Here you have
several concerns.  If you use less than full F&A, i.e., less than full
cost, aren't you using state funds to subsidize the project, and therefore
competing unfairly with commercial interests that supply the same
services?  Do you have a statewide arrangement limiting or specifying F&A
for state grant subawards or procurement contracts for state agencies?  If
you give less than full F&A in this case, aren't you just transferring
another agency's costs to your University?

Re USDA and deviating on administrative grants, you'd better have them show
you the statutory basis for limited F&A -- which we all know is "maximum
19% of total cost" for their competitive grants.

Murky little problem, isn't it!?!  State agencies usually say, "No indirect
between state agencies", with absolutely no knowledge that the methods of
calculating F&A are significantly different as between "state" and
"university".  That is one reason that the feds require use of the cost
principles of the final recipient of the funds.

Good hunting!  There are lots of us out here who are getting screwed by our
state agencies!!

Chuck

At 09:28 AM 11/8/2002 -0600, you wrote:
>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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