A-21 applies solely to federal funds, whether prime awards or
flow-down.  Many institutions have internal or other externally imposed,
policies on allowability which are similar, but usually also have funds
without these limitations.  Note that some costs allowable under A-21must
be indirect rather than direct costs; some of that depends on the structure
of your F&A agreement with your cognizant agency.

If the programs you mention are federally funded, A-21 applies, as to
charges allowable against federal funds.  The projects might have at their
disposal funds which do not have these limits.  They must clearly
differentiate the accounts to which the charges are made.  Allowability of
costs is directly tied to funding sources.

Certain costs which are largely unallowable as direct costs might be if
specifically budgeted and justified in proposals and the proposal is
accepted by the funding agency.  F 6 (b) costs are an example; in some
cases they may be directly related to the project.

Sounds as if you need clear internal rules on what may and what may not be
spent on projects, with provision for clear documentation of "grey"areas.

Chuck

At 03:36 PM 3/2/2004, you wrote:
>We have a department on campus that runs workshops and externally
>sponsored programs to promote such things as minorities in engineering,
>women in engineering, programs to improve student retention and so
>on.  Their spending habits give our accounting department grey hair.  They
>purchase items such as small gifts and promotional materials for these
>programs and gifts for volunteers that act as peer mentors etc.
>
>The question is this, since these are non allowable expenditures as per
>A-21, does A-21 apply to programs of this nature and if so how do you
>reconcile these kind of expenditure activities which are essential to the
>operation of these types of programs?
>
>Mike
>Michael P. Gilles
>Senior Contracts Analyst
>Research & Sponsored Programs
>Michigan Technological University
>1400 Townsend Drive
>Houghton, MI 49931
>Ph: 906 487-2225  Fx: 906 487-2245
>
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Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
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Fax     804-828-2051
e-mail xxxxxx@vcu.edu

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