National Science Foundation Interpretation of A-21 Changes
The National Science Foundation has made an internal decision on how
to handle the rebudgeting of costs which may involve clerical and administrative
staff. NSF has resolved its earlier doubts in favor of allowing grantee
institutions to make these decisions, consistent with 0MB published criteria
and examples (see July 1994 clarification of F.6.b by 0MB). No prior agency
approval will be expected by NSF. This decision means that now both NIH
and NSF follow the same principle of placing responsibility with universities.
This is the key point NSF makes: situations may arise where a proposal
did not anticipate the need to directly charge clerical or administrative
salaries. In such instances, grantees may rebudget funds to cover these
costs using their expanded rebudgeting authority, provided such rebudgeting
is consistent with the criteria and examples included in the 0MB memorandum
cited above NSF has not yet issued a public statement of this policy decision.
Source:Kate Phillips, Council on Governmental Relations,
NACUBO December 13, 1994
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