Deborah Moon and Donald Wood are right.  The comments
in my July 15 posting about the FAR CAS disclosure
requirements do not apply to the new A-21 CAS disclosure
requirement.

Interestingly, it looks to me as if subcontracts, which are
included in the FAR definition of covered agreements, might
not be included in the A-21 definition.  A-21 defines
sponsored agreements as "any grant, contract, or other
agreement between the institution and the Federal
Government."

Jim Simpson
General Counsel
California Public Health Foundation
2001 Addison St., Ste. 210
Berkeley, CA 94704
(510) 644-8200
FAX (510) 644-9319
xxxxxx@publichealth.org