I’m also interested in hearing more about how others are calculating. There can be a significant difference between awards and expenditures. I found USASpending sloppy and hard to navigate. Since our expenditures are just below $50M, whether they expect use of award data versus expenditures means the difference between being a covered institution or not, and obviously impacts our projections for exactly when in the future we’ll be required to comply.

Naomi E. Coll, MPH, CPH, CIP
Director of Research Policy and Compliance
Lehigh University