In the closeout section of A110 as revised, (___.71 b.) It states
"Unless the Federal awarding agency authorizes an extension, a
recipient shall LIQUIDATE ALL OBLIGATIONS incurred under the award
not later than 90 calendar days after the FUNDING PERIOD or the date
of completion as specified in the terms and conditions of the award
or in agency implementing regulations." In the previous issuance
of A-110 (K.c.) they were not as specific about liquidation; they basically
stated that the federal sponsoring agency shall obtain from the reciient within
90 calendar days after the date of completion of the agreement all financial,
performance or other reports required as a condition of the agreement.

The PHS Grants Policy Statement in the past only required that
FINAL FSRs not include any unliquidated obligations.  However, if I read
the OMB definition of "funding period" correctly, this means that ANNUAL
FSRs filed for each budget period cannot have unliquidated obligations.
This is not really a problem for accounts with automatic carryforward, but
we have many CDC and HRSA grants that do not allow automatic carryforward
of balances or obligations.  We have many subcontracts (hundreds) on these
grants that do not have end dates that coincide with the end of each
budget period.  This has never been a problem because the PHS Grants
Policy Statement (8-21) permitted filing of annual FSRs with obligated
amounts and then subsequent filing of amended FSRs within 15 months
from the end of the applicable budget period.

If this change to A-110 flows down to the PHS implementing policy, we
see this as having a major impact--We submitted comments to this
effect during the comment period; however, they were not addressed
in the final issuance.

Has anyone else out there noted this as a concern?  Am I misreading the
definition of "funding period" to equate to budget period?

* Elizabeth (Liz) Mazzella             xxxxxx@ALBNYDH2.BITNET  *
* Asst. Dir. Technology Transfer & Sponsored Pgms.            *
* Health Research, Inc. 66 Hackett Blvd. Albany NY 12209      *
* Voice: (518) 431-1200                    Fax: (518)431-1234 *