Does anyone have experience with High Intensity Drug Trafficking Area
cooperative agreements funded through the Office of National Drug Control
Policy (ONDCP, a division of federal Executive Office)?  Our regional HIDTA
has subcontracted with us for drug prevention activities and in the
agreement we are required to submit copies of all purchasing invoices,
payroll reports, and travel documents for reimbursement.   In addition, they
define equipment as anything over $500 and anything that meets this
definition belongs to HIDTA and we must inventory the equipment using HIDTA
inventorying processes, not our institutional definition or processes.  The
regional HIDTA is only flowing down to us what they have accepted from the
ONDCP.  The agreement was one that was signed without complete review, so we
are stuck with these terms at this point, but it seems that this is in
conflict with OMB Circular A-110 and A-87/A-21 which are also part of the
prime's agreement.  My concern centers around the fact that the HIDTA
procedures appear to be contrary to OMB Circular A-110, Subpart A that
states "Federal awarding agencies shall not impose additional or
inconsistent requirements, except as provided in Sections ___.4, and ___.14
or unless specifically required by Federal statute or executive order."  I
also have concerns regarding the equipment definition ($500) and the request
that the equipment be maintained on the prime's inventory system.

Any input or suggested course of action would be appreciated.   At present
our approach is to try to find alternative funding to carry out the same
activities (we have one staff person who was hired just to operate this
program and who will lose her job if we choose to terminate the agreement).

____________________________________________
Kris E. Rhodes, Grants Officer
Marshall University Research Corporation
400 Hal Greer Blvd., 212 GH
Huntington, WV 25705
Phone 304/696-4837; Fax 304/696-4747
Email: xxxxxx@marshall.edu

Go Marshall Thundering Herd !!!
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