I tend to agree with Patricia on this one.

A-76 is "Performance of Commercial Activities" with its purpose noted as
"This circular establishes federal policy for the competition of
commercial activities."  Its primary function appears to be letting the
private sector be subject to the forces of competition and not receive
undue/overdue influence of the government in commercial activity.

I would suggest the following references for For-profit companies:
Cost Principles: 48 CFR, Chapter 1, Part 31
Administrative Requirements: 29 CFR, Part 95
Audit Requirements: 29 CFR, Part 96

Regards,
Michael DeShazo, CRA
~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=
Budget/Fiscal Analyst Lead
Fiscal Compliance and Outreach, RAA
University of Washington, Box 351122

Team Email: xxxxxx@u.washington.edu

PH: (206) 616-6718
FX: (206) 543-0764
EM: xxxxxx@u.washington.edu

WEB: http://www.washington.edu/research/gca/office/
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Hawk, Patricia said the following on 10/9/2006 8:20 AM:
> 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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