NOT-OD-26-072
NIH has updated its implementation of 2 CFR Part 200 (Uniform Administrative Requirements) as reflected in the FY26 NIH Grants Policy Statement.
Key Points:
- While 2024 updates to 2 CFR Part 200 have been incorporated into NIH policy, certain indirect cost provisions will not be implemented at this time due to the FY2026 appropriations law.
- NIH will continue to follow existing indirect cost requirements under 45 CFR 75, rather than updated thresholds in 2 CFR 200.
- As a result, previously announced flexibilities are rescinded, including:
The updated Modified Total Direct Cost (MTDC) definition (including the $50,000 subaward threshold); and
The updated 15% de minimis indirect cost rate.
Current rates in effect based on the guidance for UCSF
MTDC, including up to the first $25,000 of each subaward.
This is in line with UCSF's current Federally Negotiated Indirect Cost Rate Agreement and is not a change in process.
A 10% de minimis indirect cost rate for eligible entities without a negotiated rate.
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