Hi Ron,

Maybe I missed part of this discussion, but ALL of the
OMB Circulars are Common Rules and are applicable to
the federal agencies.  Federal agencies are required
to make the Common Rules applicable to grantees
through agency implmentation via a CFR.  Some agencies
merely indicate they are implementing the specified
OMB Circular in its as originally referenced in its
entirity.  With PL 106-107 the OMB Circular are being
incorporated into 2 CFR to make them easier to locate.

OMB Circular are the original effort by the federal
government to streamline grants management and create
consistency across agencies.  Except when an exception
to an OMB Circular is granted (or state agencies have
a complete waiver option for block grants), agencies
are not suppose to implement more stringent management
requirements than those outlined in the the circulars.

The specific circular you cited in a A-102 is "Grants
and Cooperative Agreements with State and Local
Governments."  A complete list of OMB Common Rule
Circulars are available at
http://www.whitehouse.gov/omb/circulars/index.html.

Kris Rhodes
Director, Grants Administration
Wake Forest University Health Sciences

--- Ronald Park <xxxxxx@IUP.EDU> wrote:

> Just a quick verification. While attending sessions
> at the SRA meeting this
> week I heard a number of times references to the
> Common Rule. I have
> identified an OMB Circular (A-102) that is called
> the common rule and wanted
> to make sure that this is the correct "common rule".
> Can someone verify for
> me? Thanks!
>
> Ronald F. Park, Jr.
> Director of Fiscal Affairs
> IUP Research Institute
> 107D Stright Hall
> 210 South Tenth Street
> Indiana, PA  15705
> Phone 724-357-3241
> FAX 724-357-7697
> xxxxxx@iup.edu
>
>
>
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