We will soon be undergoing our A-133 audit.  Please help clarify when
"cluster" should be applied or not applied in a small research institution
setting.

We are a small hospital based research program that is subcontracted
for all our federal grants to a state medical school.  We have 11 research
grants from  three federal agencies.  We have one program project with
NASA that accounts for 50% of our grant receipts.  We have passed the
$300K audit threshold.

Our audit firm is trying to determine if all our grants are to be one
"cluster".  If that is true how can the new  A-133 rules for low risk (25%
audited) versus high risk (50% audited) be applied?  Is all R&D always
considered as a cluster?  Or do "clusters" apply for large organizations
like states who have block grants for child welfare, education, etc.

Thank you for your time!