Linda,

I agree with you.  Realistically, I doubt very seriously that a PI is
going to review A-21 to ensure expenditures are allowable.  I believe as
long as the University is consistent with their respective policies and
the sponsor is aware of such purchases then there should not be an
issue.

I assume that controls are already in place to address allowability
issues or else the lack of controls would have been cited.  I could only
suggest that a training program (which would be mandatory) be required
for PIs conducting research.  I am an advocate of such training as long
as it is mandatory...anything less and PIs would not show up or take the
training.  In addition, training could be offered online and taken at
any time.

What controls are they referring to in A-133?

Best Regards,

David Dockwiller
Manager, Contracts and Grants
The University of Texas at Austin

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org] On
Behalf Of Linda Manley
Sent: Friday, October 27, 2006 9:28 AM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] PI review of circulars

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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