Our college recently received a federal contract stating that "allowability of
costs...will be determined in accordance with OMB circular A-21...limited to
the items of expenditure set forth above...." One of these items is for
"maintenance expenses" for participants travelling outside the country for long
periods.  Because the line consists of a significant portion of the budget,
we sought confirmation from the agency that we can pay the travellers via a
per diem allowance, instead of reimbursing them for actual expenses
(requiring receipts).  In speaking to two individuals at the agency, however,
we received two contradictory interpretations.  If there is anyone who has
experience with an auditor's interpretation of "maintenance expenses", or can
otherwise shed light on which of the following interpretations is correct, I
will very much appreciate your comments.

One interpretation we received is that A-21 (section J.48.a) treats
"maintenance expenses," "travel costs", "maintenance/per diem" and "living
expenses" as interchangeable and thus our award would only require that we are
consistent in using one method or the other on a trip.  The other
interpretation is that the terms are not interchangable, and thus the language
of our award restricts us to use of "maintenance expenses" that are
reimbursements backed by receipts.

Thanks in advance for any words of experience.

Mary Louise Pauli
Director, Office of Sponsored Programs
Bentley College
Waltham, MA