I called OPERA to confirm this new twist on the definition.
 It was confirmed.  Depending on how you interpret,
 this gives us more freedom.  The prior definition required
 us to report when we anticipated a 25% or $250,000
 threshold, whichever is less, for all categories combined,
 now we have to reach it for one.  Example: Total budget of
 $200,000 (Direct & Indirect).  You would have to rebudget
 one single category by $50,000 before notification in the
 continuation application is required.

          However, I do think that the rebudgeting policy is now very
          confusing.  The PHS Grants Policy Statement says one thing
          and the new definition came out in relationship to SNAP (NIH
          Guide, Volume 24, Number 38, October 27, '95).