Hi Linda,

Did your auditor interview the PI to test their knowledge of A-21?  If yes,
then your auditor was wasting time.  If no, they are making an assumption
which is a waste of your time.

Does your auditor know that grants are granted to institutions and not
individuals thus the responsibility for knowledge of, understanding and
applying A-21 is the responsibility of the institution?  If yes, they
should know better than to raise this point.  If no, they should know much
more than better.

For the sake of argument if your PI is an A-21 expert does he/she know
about the "consistency" of the expenses across the institution?  If yes,
he/she is not doing research because he/she spends all his/her time in the
accounting offices.  If no, the he/she is doing what he/she is paid to do
and not using federal funds to support his/her administrative role policing
expenditures.

If this situation was on my desk I would be discussing the auditors
ability/comments with their supervisor.

Dan

At 10:29 AM 10/27/2006, Linda Manley wrote:
>David: I have no clue as to what controls they are referring to. Here's one
>of the statements in the management comment: "Equipment grant were not
>reviewed for accordance with the applicable OMB Circular A-21, Educational
>Institutions as outlined in the OMB Circular A-133 Compliance Supplement."
>If I'm not mistaken, Part B "Allowable Costs/Cost Principles" of the A-133
>Compliance Supplement just refers you to the OMB Circular A-21, which
>incorporates the 4 items I listed before. We just keep going around in
>circles!
>
>We offer training to PI's but it is not mandatory. I'll propose your
>suggestion to the higher powers than me. Thanks for the feeback.
>
>
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