Dear Colleagues,

We are trying to negotiate a subcontract from another university under a
U.S. Department of Education grant.  The other university, also the prime
grantee, insists upon using state law equivalents for drug free workplace,
debarment/suspension, delinquency on debt, and other certifications.

This is unique in my experience and legal counsel for the other university
is quite persistent in keeping the state law references.  We asked about
the basis for doing so as it is a federal grant to directly to the
individual university, rather than Dept of Ed to The State then to The
University, and received a non-responsive answer.

I have two questions.  First, has anyone else encountered this sort of
situation?  If so, how did you handle it and what was the outcome.  Second,
is there something in EDGAR that allows (or prohibits) substituting
certifications under state law in a subcontract?

Any suggestions will be much appreciated.

Best regards,

Ruth Smith, Executive Director
Old Dominion University Research Foundation
P.O. Box 6369; Norfolk, VA 23508
Ph 757-683-4293, ext. 600
Fax 757-683-5290
Mobile Ph 757-469-5675

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================