I would be interested in hearing how other universities handle the
consistency requirement of A-21 as it relates to allowability, allocability
and reasonableness of costs charged to a sponsored project.  A recent
meeting on the upcoming unallowability of dependents' tuition prompted the
question:  Will we be able to charge dependents's tuition to non-federal
sponsored projects?  My response was "no," but other members of the group
disagreed with me.  They seem to think that A-21 only pertains to federally
sponsored projects, which, as you know, it doesn't.
 This same meeting brought to light the fact that our practice has been
at the termination of a fixed-price sponsored project to transfer unexpended
funds into an unrestricted account, where they can be spent on ANYTHING.  I
don't think this is legit.  Am I right?

Georgia Rothacker
Research Administrator
RIT Research Corporation
125 Tech Park Drive
Rochester, NY  14623-2435
Phone:  716-239-6005  Fax:  716-239-6019
xxxxxx@rc.rit.edu