AAMC Strongly Opposes OMB
Cost Principles Harmonization Proposal
October 18, 2002-The AAMC Oct. 10 responded
to an Office of Management and Budget (OMB) proposal revising
OMB cost principles in an effort to bring some uniformity
to Circulars A-21, A-87 and A-122. Although OMB professed
not to be making any policy changes in the notice, significant
changes were proposed in the effort to harmonize the circulars.
As a result, AAMC concluded, "that the current OMB proposal
to streamline the cost principles is too far reaching and
clearly and inappropriately steps over the line into the area
of policy change. We join with others in the research community
in urging OMB to withdraw the proposal."
AAMC's response benefited from an extensive review of the
proposed revision performed by the Council on Government Relations
(COGR). AAMC endorsed COGR's detailed comment letter and highlighted
several concerns:
- AAMC objected to the proposed revisions that would mandate
that the "original complement of low cost equipment"
required to outfit a new facility/building would have to
be capitalized, regardless of the cost. AAMC said, "This
would create a significant and costly burden for university
administration, faculty, and research staff without apparent
benefit and is unnecessary."
- A new section of the circulars would have the effect
of making currently allowable interest costs unallowable.
OMB revised the interest provisions of A-21 in 1996 to establish
more rigid criteria for reimbursement of interest costs,
but the 1996 revision did not eliminate the allowability
of interest costs incurred prior to that date. AAMC strongly
opposed this change.
- AAMC opposed a provision that would require prior agency
approval for foreign travel.
AAMC concluded its comments by strongly requesting "that
OMB reconsider its approach and consult with the research
community before proceeding further."
Information:
Tony Mazzaschi, Senior Associate Vice President
AAMC Biomedical Health Sciences Research
tmazzaschi@aamc.org
(202) 828-0059
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