Effective August 27, 1997, the Department of Education (DED) has amended Part 75 of the Education Department General Administrative Regulations (EDGAR). This publication spells out the policies and guidelines that govern the administration of DED grants and cooperative agreements.

These amendments now provide "expanded authorities" to DED grantees, similar to the provisions of the Federal Demonstration Partnership adopted by many other federal agencies. The expanded authorities will lead to reduced paperwork and reduced regulatory burdens for grantees. The Federal Register dated July 28, 1997, provides the detail on these changes. We are summarizing the changes below.

As stated in the Federal Register, these new provisions apply to most grants and cooperative agreements outstanding as of August 27, 1997, and to grants and cooperative agreements made on or after that date. There are a few exceptions to the 8/27/97 date, notably some programs funded by the National Institute on Disability and Rehabilitation Research (NIDRR). Those programs are scheduled to fall under the DED expanded authorities on October 1, 1997 WITH THE EXCEPTION OF TIME EXTENSIONS. NIDRR grants will continue to require DED prior approval for extension of grants past the end of the project period.

Effective immediately, unless DED notes otherwise on the award notice, the following cost-related and administrative prior written approvals are hereby waived:

1. Pre-award Costs. Recipients may incur pre-award costs 90 calendar days prior to the award begin date. Pre-award costs incurred more than 90 days prior to award begin date require prior approval from DED. All pre-award costs are incurred at the recipient's risk (i.e. DED is under no obligation to reimburse such costs if for any reason the recipient does not receive an award or if the award is less than anticipated and inadequate to cover such costs.) PI's wishing to use the pre-award feature on new or renewal grants must submit Form 88-1, "Request for Assignment of Account Number in Advance of Award".
   
   
2. No-Cost Time Extensions. A single extension, which shall not exceed twelve (12) months, may be granted by the University to the PI if it is required to assure adequate completion of the original scope of work within the funds already made available. The request, in letter format, must be received by Research and Sponsored Programs (RSP) far enough in advance to allow RSP to notify the awarding DED official at least ten (10) days prior to the original termination date. The letter to RSP must contain supporting reasons for the need for the extension. The fact that funds remain at the termination date is not in itself sufficient justification for an extension.
   
   
3. Carryover of Unexpended Balances. Any unobligated balance of funds remaining at the end of a budget period will be automatically carried forward to the next budget period and may be used to defray future costs of the project. Funding remaining at the end of a project period (competitive segment) is not eligible for automatic carryover. As a result of this change, fund/account numbers will now remain the same throughout the total project period, except in unusual circumstances.
   
   
4. Cost-related Prior Approvals. Cost-related and administrative Federal prior approvals required by OMB Circulars A-21 and A-110 (i.e. foreign travel, permanent equipment, etc.) are waived as long as the University continues to maintain adequate internal administrative systems (accounting control, purchasing, etc.). The waiver does not include changes in scope of work, subcontracting, changes in key personnel or transfer of funds allotted for training allowances to other categories of expense. Those types of changes still require a letter from the PI to DED, countersigned by an RSP official.
   
   
5. Total Budget Concept. The language in the March 6, 1997 version of EDGAR 74.25(c)(5), states that DED approval is necessary for the use of indirect costs to absorb increases in direct costs, or vice versa only if approval is required as a written condition on the notice of grant award. This language represents a welcome change in DED policy and allows the University to consider direct and indirect costs as a total awarded amount. While this action allows PI's much greater flexibility, please keep in mind that we cannot request additional indirect costs brought about by rebudgeting.

These actions taken by the Department of Education provide PI's with increased flexibility and are welcome steps toward reducing both administrative paperwork and time. Please call Robert Andresent at 608-262-2896 for additional information.