I have always thought the purpose of OMB Circular A-76 was to establish
Federal policies and procedures for competition of commercial
activities performed by the Federal government.  If you remember a few
years ago, NIH went through the "A-76 process" for "competing" their
grant management functions.

I never thought of it as cost principles, but rather the guidelines a
Federal agency and competing commercial firms must follow in order to
determine if these commercial activities could be performed by the
private sector in a contract or fee-for-service arrangement.

Pat

Patricia A. Hawk
Assistant Director
Office of Sponsored Programs
 and Research Compliance
Oregon State University
312 Kerr Administration Building
Corvallis, OR  97331-2140
541-737-6699 (voice)
541-737-3093 (fax)

________________________________

From: Research Administration List [mailto:xxxxxx@hrinet.org] On
Behalf Of Kathleen Reneau Lorenzi
Sent: Monday, October 09, 2006 7:27 AM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] OBM circulars A-76 versus A-133

Commercial organizations are subject to the cost principles of A-76.
Info can also be found at 48 CFR 31.2 and FAR Part 31.2.  A-133 does not
apply to commercial organization because they are subject to very
different cost principals than non-profits and universities.  If they
are subject to Cost Accounting standards, commercial organizations have
20 some-odd CAS requirements as oppose to the 4 that apply to
universities.  Commercial organizations also have fluid overhead rates
and very different close-out procedures than universities.

Also check 48 CFR 34.

FDP has a nice matrix on the web at
http://www.nsf.gov/pubs/fdp/fdpappa02.pdf  that identifies the various
requirements for subcontractors in each situation.

Hope this helps,

Kathy

Kathleen Reneau Lorenzi, CPCM

The University of Texas at Austin

Office of Sponsored Projects

P    512-471-2335

F    512-471-6564

E    xxxxxx@austin.utexas.edu <mailto:xxxxxx@austin.utexas.edu>

________________________________

From: Research Administration List [mailto:xxxxxx@hrinet.org] On
Behalf Of Bonnie Kwit
Sent: Monday, October 09, 2006 8:16 AM
To: xxxxxx@hrinet.org
Subject: [RESADM-L] OBM circulars A-76 versus A-133

We have a for-profit as a subcontract to us under a federal grant.  This
for-profit company is telling me they do not and will not follow A-133
and follow A-76.  Is anyone familiar with A-76,  and don't we have to
pass down A-133?

Bonnie Kwit

Grants & Contracts Officer

Oakland University

544 O'Dowd Hall

(248) 370-4116

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 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")
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