We are not sure ourselves that what they mean by "formally". I made a
comment to them that it seemed unreasonable that to me that they actually
think that before an expenditure would be charged to a grant, that any PI
would pull out the A-21 and look at it and think "yes, this is allowable".
Maybe I'm way off in my thinking and they do at other universities? She
acknowledged that all 4 tests (reasonableness, allowability, allocability
and consistency) of A-21 were met. Their wording of the management comment
is ".....all expenditures were allowable under Circular A-21 resulting in
no questioned costs. However, controls as outlined in OMB Circular A-133
were not in place to ensure compliance". Their recommendation is "The
private investigator should monitor grant expenditures for allowability
under OMB Circular A-21 as the expendtures are incurred. PI's reveiw of
expenditures for allowability under Circular A-21 should be monitored by
the University to ensure compliance is met."

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