We are under A-122 and have always (at least in the 5 years I have been
here) had the policy that we use the lesser of our negotiated rate from DHHS
or the rate listed in the grant award.  Our outside auditors approve of this
practice, and to date no agencies have complained about it either.  And of
course PI's are thrilled when they are allowed to rebudget to direct costs
due to the implementation of a lower indirect rate.

Darri L. Snodgrass
Director of Research Support Center
Arkansas Children's Hospital Research Institute
1120 Marshall Street
Little Rock, Arkansas 72202-3591
Phone:  (501) 320-3581     Fax:  (501) 320-3547
E-Mail:  xxxxxx@exchange.uams.edu

-----------------------
Date:    Wed, 11 Nov 1998 11:28:30 -0600
From:    Martha Taylor <xxxxxx@MAIL.AUBURN.EDU>
Subject: A-21 &F&A  rates for the life of the spon ag

Dear RESADM-L-ers:

We have a small difference of opinion here today about A-21 and the
requirements in section G.7. about fixed F&A rates for the life of a
sponsored agreement.  I would like to survey the group and ask for a
response to the following multiple choice question.  How do you handle the
requirements in G.7. when your rate changes?  (choose one)
A.      We leave the rate exactly the way it was at the time the award was
signed and became effective.
B.      We change the rate down whenever a new lower rate becomes effective
regardless of what the regulations say or the budget will support.
C.      If we know in advance of award acceptance that our rate will change
on a
date certain, we negotiate the changes when we negotiate the award and then
change the rate when the rate becomes effective.
D.      We leave the rate exactly as it was proposed and awarded for all
years
until we have to resubmit a competing continuation/renewal proposal.
E.      Other (please provide brief explanation)

------------------------------

Date:    Wed, 11 Nov 1998 12:23:33 -0800
From:    Julia Stewart <xxxxxx@NCCF.ORG>
Subject: Re: A-21 &F&A  rates for the life of the spon ag

What about A-122?=A0 Also, I have had A-133 audits where it was
required we change the rate in the middle of the project year due to a lower
(provisional) rate being awarded (e.g. grant awarded at 50%, which was
the rate in effect at the time of issue, but negotiated rate with DHHS
awarded later at 45.3%). What option applies?