These subcommittee and COGR successes demonstrated that there was mutual understanding that the university leaders should write the revisions of A-110 in simple and clear language for research administrators.
He explained to his colleague at Georgetown, Sam Kimble, that "Recognizing the futility of assigning this task to a federal employee," Palmer Marcantonio at OMB had suggested that COGR write the first draft of "a re-write" for subcommittee consideration.
Frick's comments were part of a subcommittee report for Reagan Scurlock at COGR.
This incorporation, by law, would enable public comments; and COGR should make strong efforts to get this problem resolved.
Warner noted in the margin that he was contacting George Northway to draft a COGR letter on this issue (Warner Papers, Cowen, 1977, December 21; O'Brien, 1977, December 2).
With the NASA issue unsettled, Margery Hoppin, acting on behalf of the subcommittee, wrote to Reagan Scurlock at COGR, a summary memorandum about the DHEW's proposed revisions to A-110, particularly in the area of property purchased by grantees.
In sum, the OMB granted the only DHEW deviation to the Office of Education (then known as OE) on a matter that COGR had argued was outside the realm of research administration, as it is today.
As disclosed, by the fall of 1978, property standards required in A-110 were the remaining point of contention between COGR and OMB.
Hoppin of Iowa had prepared an unsuccessful revision for COGR in March 1977 that requested deletion of the provision; and currently "HEW does not interpret the circulars as prohibiting this requirement; OMB agrees.
Much of this crept into COGR positions prepared during the public comment period for new principles because, as chair of the Grant and Contract Provisions Committee, he drafted the COGR letters.