Another question....this time about the new A-21 section G.2. --
specifically tuition remission and IDC on subawards.

"Equipment, capital expenditures, charges for patient care and tuition
remission......shall be excluded from MTDC."

TUITION REMISSION:

Our current DHHS rate agreement DOES NOT exclude tuition remission from the
base.  We therefore have been charging IDC on tuition/fees when they appear
as a line item on the budget.

Question....our current rate agreement is in effect until 8/31/96!  Which
takes precedence?  Will DHHS amend our rate agreement due to the revised
A-21?  Do we follow A-21 and ignor our rate agreement or ignor A-21?

SUBAWARDS:

This involves that age-old question of subRECIPIENTS vs subCONTRACTS.  We
have been assuming that the "subcontracts and subgrants" indicated by A-21
et al REALLY mean subRECIPIENT and use the <$25k rule for those type of
agreements only.  We define subCONTRACTS as vendor relationships and change
full IDC on subCONTRACTS.

Now we've been asked if that is correct, and I come back to wanting a
definition of subR vs subC, and if A-21 means ANYTHING that is a subawards
regardless of subC or subR.  Comments?

 Thanks.  Jean.

Jean N. Humphries
Director, TEES Research Services
Texas Engineering Experiment Station

The Texas A&M University System
308 Wisenbaker Engineering Research Center
College Station, TX 77843-3000

Telephone:  (409) 845-1264
Fax:  (409) 845-9643
Email: xxxxxx@tamu.edu