Carryover and other "expanded authorities" were included in the Final Rule
for Direct Grant Programs published in the July 28, 1997, Federal Register.
This is the URL:
http://www.ed.gov/legislation/FedRegister/finrule/1997-3/072897a.html
It has not been an easy task to get consistency on the interpretation of
this rule, as different divisions have had their own "takes" on when prior
approvals are needed and when they are not.   At first reading, it appeared
that USDE was finally moving toward FDP, and really cutting down prior
approvals.  However, the rule has "escape clauses" that render it nearly
useless under interpretations by some programs and program officers.  I
corresponded a few times with the Office of the Chief Financial Officer,
where the rule was written, to seek guidance.  The following e-mail was
received from Art Stewart of that office on March 25, 1998, in response to a
question about transfers between indirect and direct costs.  "I need to
clarify (c)(5).  According to the author of that section, the language 'if
approval is required by the Secretary' means that the Secretary must state
that the transfer of amounts budgeted for indirect to absorb increases in
direct costs [one of the expanded authorities], or vice versa requires prior
approval.  If the Secretary doesn't say anything about this one particular
section, it's okay to go ahead and make this type of transfer.  However, all
other sections under 74.25(c) work in the reverse.  The Secretary has to
specifically state that the prior approval requirements are waived."  When
an award agrees with this OCFO interpretation, I proceed with expanded
authorities and send a notification letter to the program officer stating
the action I've taken, e.g., carryover. Otherwise, I seek prior approval.
I'd be interested in how others of you are handling this.  Off-line would be
fine.  Thanks.  Donna

Donna Roxey, Associate Director
Office of Grants and Contracts
The Ohio State University Research Foundation
1960 Kenny Road
Columbus, OH 43210-1063
Tel:  614-292-6471; Fax: 292-4315; xxxxxx@osu.edu

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