Unfortunately, you are looking at two DIFFERENT circulares; A-21 and
A-110.  A-21, obviously, deals with cost principles and therefore
allowability while A-110 deals with management standards.  Expectations
were (when I was still with the Navy) and, I assume it is still the
intention, are to revise that provision of A-21 to come in line with
A-110.

When will that change happen?  I don't know; will it rain on the twelveth
of Never?

On Wed, 3 May 1995, Doug Wilkerson, Ph.D. wrote:

>          Unless I missed something A-21 still defines equipment as anything
> costing over $500, etc.  However, the April 28 issue of the NIH Guide, in
> a section entitled "Commonly Asked Questions About Equipment Under Grants"
> defers to the definition of equipment contained in 45 CFR Parts 74 and 92 whic
h
> defines equipment as
>
> "tangible nonexpendable personal property having a
> useful life of more than one year and an acquisition cost of $5,000 or more
> per unit. However, consistent with organizational policy, lower limits may be
> established.  GRANTEES MAY IMPLEMENT THE NEW DEFINITION (PROVIDED THEY DO SO
> CONSISTENTLY ON AN ORGANIZATION-WIDE BASIS) EVEN THOUGH THE DEFINITION IN
> THE COST PRINCIPLES MAY NOT YET CORRESPOND. (45 CFR PART 74.2 AND 74.34)"
>
>         Does this now mean that the A-21 definition no longer applies?
>
> Doug Wilkerson, Ph.D.           VOICE:  (419) 381-4252
> Assoc. V.P. for Research        FAX:    (419) 381-4262
> Professor of Pharmacology       e-mail: xxxxxx@GEMINI.MCO.EDU
> Medical College of Ohio
> 3000 Arlington Ave.
> Toledo, OH 43614