I have just returned from Seattle & NCURA's 2nd conference on
regulatory affairs.  A great deal of the discussion related to: 1)
consistency in documenting direct costs; and 2) the revision of A-21
concerning the elimination of "secretarial costs" as an allowable cost.

 My sense of why no one responded directly to the list in response to
the first notice is that the proposal is not defenseable and cannot be
justified.  I did respond with the following short note to the original
poster, but have received no response back.

 "My initial reaction is one of doubt; could you share to the list
where you would argue this fits in the direct cost categories as outlined
in A-21.  I am symathetic, but this seems to stretch the cost principles."

 I believe this sort of practice would undoubtedly be challenged
through a "systems" audit.  Given time, I could offer a more in-depth
explanation or justication of my rationale.

Terry A. May, Ph.D.                       Voice:    602-523-6788
  Director of Research Administration     FAX:      602-523-1075
  Office of Grant & Contract Services     INTERNET: xxxxxx@nauvax.ucc.nau.edu
  100 Babbitt Admin. Ctr., Box 4130
  Northern Arizona University
  Flagstaff, AZ  86011-4130