EDGAR, Part 75 Alexandra Garrison 24 Oct 1997 15:33 EST

A query from Richard Louth (xxxxxx@nyu.edu)at the Office of
Sponsored Programs as NYU. Replies please directly to Richard or to Alex
(see signature at end of message).

We're interested in knowing how others are interpreting/implementing the
7/28/97 revisions to EDGAR, Part 75, expanding grantee prior approval
authority for carryovers and no-cost extensions on DED grants not otherwise
limited by specific regulation.

It was our understanding that the revisions were intended to reconcile Part
75 with the previous Part 74 implementation of changes to A-110, and, like
Part 74, to extend such authority automatically only in the case of
research programs, and that application to training programs would require
further action by the Secretary.  According to COGR, however, which has
consulted a DED policy officer, the July 29 revisions constitute that
additional action.

To add to the confusion, different DED program officers seem to be applying
their own interpretation, and have given us mixed advice on specific
postaward changes in training grants.

What has been your experience with DED?  Have you changed your prior
approval system with regard to DED grants?  If so, across the board?

Alexandra Garrison, Ph.D.
Office of Sponsored Programs
New York University
15 Washington Place, #1H
New York, NY 10003
Tel: 212/998-2123
FAX: 212/995-4029
E-Mail: xxxxxx@nyu.edu