My institution (under A-122) uses two standard sets of travel
reimbursement rates--the state mandated per diems for state appropriated
dollars and the Federal rates for all sponsored research activity and
travel funded by our indirect cost recovery.  A-122 says travel costs
"may be charged to federal grants on an actual basis, on a per diem or
mileage basis in lieu of actual costs incurred, or on a combination of
the two, provided the method used results in charges consistent with
those normally allowed by the organization in its regular operations."
I suppose there is some room for interpretation of the words "regular
operations."  We are a dedicated non-teaching public research institute
(part of the system of higher education) and receive only 25% of our
funding from the state.  About 75% of the other 75% comes from the
feds.  So, I suppose, based on the numbers, one could perhaps say that
our "regular operations"--or at least the majority of our
operations--our those that are funded by federal dollars.  But I have
always been under the impression (from my A-21 experience) that the
circulars require us to spend federal dollars in the same way, and
subject to the same limitations, as our state appropriated dollars if we
are a state entity.  Otherwise, we are charging the federal government
more for the same trip than we would have paid from our own state
appropriated funds.  To complicate matters even further, we have been
accepting other states' travel rates, which are usually in between the
Federal rate and the very low Nevada state rate, on a project by project
basis...and this creates bit of a nightmare for our travel reimbursement
clerk.  I think we have an A-122 consistency problem, but I'd like to
know what my colleagues think.  Am I missing something?
Thanks.
Barbara

--
Barbara H. Gray
Director of Sponsored Research
Desert Research Institute
2215 Raggio Parkway
Reno, Nevada  89512-1095
Telephone:	775-673-7381
Fax:		775-673-7459
E-mail:	xxxxxx@dri.edu
www.dri.edu

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