Yes, a contract is not a grant but to quote Section A.1 of Circular A-21
"This circular provides sprinciples for determining the costs applicable
to research and development, training, and other sponsored work performed
by colleges and universities under grants, contracts, and other agreements with
the Federal Government."

So, I conclude the interim rule has nothing to do with the applicablity of the
26% cap since that's in A-21.  It will not govern the "pause" since that bad
idea will be statutory if it is passed.  It MAY prevent the practice of some
DOD buyers to attempt to get the university to cost-share all or a portion of
IDCs.  This has also been particularly true of some subcontractors' buyers!
At least now we have a "rule" to point to in our attempts to recover our
indirect costs.

Phil Spina
Wright State University
xxxxxx@desire.wright.edu