Perhaps one way to mitigate this, as I do for several of my non-profit and small business clients who don't have a negotiated rate and who use the 15% de minimis rate, is to move what would otherwise be classified as indirect costs into the direct cost category. Vice President of Research effort to oversee research operations? 0.5% effort on each grant. Utilities and rent or space costs? Use a space survey to calculate those costs and direct-charge them to the grant. Of course, this is like shuffling deck chairs if there is a direct cost cap, but might help when there is not.KirstenOn Mon, Feb 10, 2025 at 8:24 AM Abrego Natoli, Yvonne - yvonne.abregonatoli at wku.edu (via resadm-l list) <xxxxxx@lists.healthresearch.org> wrote:I agree, Gina. There is no understanding for the rules we abide by when accepting reduce idc rates. One of those things is that typically we are charging the federal government a MTDC rate but for reduce idc rates, typically we are charging TDC (no exclusions). There are times when charging TDC at a lower rate is more costly than charging full MTDC. The NIH announcement does not stipulate if we are to charge 15% MTDC or TDC. I bet a revised announcement will be released to clarify that.
All the best,
Von
Yvonne Abrego Natoli
Assistant Director, Pre-Award Operations
Office of Sponsored Programs
Western Kentucky University
1906 College Heights Blvd., #11026
Bowling Green, KY 42101-1026
https://www.wku.edu/sponsoredprograms/
From: Betcher, Gina - gina.betcher at oregonstate.edu (via resadm-l list) <xxxxxx@lists.healthresearch.org>
Sent: Friday, February 7, 2025 6:18 PM
To: xxxxxx@lists.healthresearch.org
Subject: [EXTERNAL] Re: [RESADM-L] NIH 15% Indirect Cap Announcement
"Indeed, one recent analysis examined what level of indirect expenses research institutions were willing to accept from funders of research. Of 72 universities in the sample, 67 universities were willing to accept research grants that had 0% indirect cost coverage. One university (Harvard University) required 15% indirect cost coverage, while a second (California Institute of Technology) required 20% indirect cost coverage. Only three universities in the sample refused to accept indirect cost rates lower than their federal indirect rate. These universities were the Massachusetts Institute of Technology, the University of Michigan, and the University of Alabama at Birmingham.
The United States should have the best medical research in the world. It is accordingly vital to ensure that as many funds as possible go towards direct scientific research costs rather than administrative overhead. NIH is accordingly imposing a standard indirect cost rate on all grants of 15% pursuant to its 45 C.F.R. 75.414(c) authority. We note in doing so that this rate is 50% higher than the 10% de minimis indirect cost rate provided in 45 C.F.R. 75.414(f) for NIH grants. We have elected to impose a higher standard indirect cost rate to reflect, among other things, both (1) the private sector indirect cost rates noted above, and (2) the de minimis cost rate of 15% in 2 C.F.R. 200.414(f) used for IHEs and nonprofits receiving grants from other agencies.
Of these two paragraphs, it appears there is no understanding for the rules we abide to accept a lower indirect cost rate. Also, of the sample universities, we have no knowledge of the number or value of grants or again the terms of the indirect policies of the sponsors.
The de minimis goes from 10% to 15% that of course we are not 50% higher.
We should all be able to disclose our average return on indirect costs and then disclose from there what is supported by indirect costs.
Gina Betcher, MFA , CPRA
Research CoordinatorCollege of Liberal Arts
Oregon State University
https://calendly.com/betcherg-oregonstate
From: Brandenburg, Nichole - Nichole.Brandenburg at osumc.edu (via resadm-l list) <xxxxxx@lists.healthresearch.org>
Sent: Friday, February 7, 2025 5:06 PM
To: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org>
Subject: Re: [RESADM-L] NIH 15% Indirect Cap Announcement
[This email originated from outside of OSU. Use caution with links and attachments.]
Yes please draft
Get Outlook for iOS
From: Moise, Jessica - jessica.moise at mssm.edu (via resadm-l list) <xxxxxx@lists.healthresearch.org>
Sent: Friday, February 7, 2025 8:04:18 PM
To: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org>
Subject: Re: [RESADM-L] NIH 15% Indirect Cap Announcement
It won’t hold up if the rule of law holds up. But the rule of law is looking mighty fragile at the moment. Courage everyone. 🥄🥄🥄🥄 Sent from my iPhone On Feb 7, 2025, at 7: 55 PM, Ken Packman <xxxxxx@ gmail. com> wrote: USE CAUTION:
It won’t hold up if the rule of law holds up. But the rule of law is looking mighty fragile at the moment.
Courage everyone.
🥄🥄🥄🥄
Sent from my iPhone
On Feb 7, 2025, at 7:55 PM, Ken Packman <xxxxxx@gmail.com> wrote:
USE CAUTION: External Message.
I don’t think this can hold up. Current grants obligate—just like contracts (which they really are)—-both parties to their terms. And prospective grants are still governed by a host of other legislation and regulations, not least the UG which has numerous references to negotiated indirects. There will be a lot of legal responses to this, and they should succeed, at least for the near future. But this is clearly a harbinger of future attacks on our institutions.
On Fri, Feb 7, 2025 at 7:09 PM Kathy Miller <xxxxxx@gmail.com> wrote:
It’s read like it’s now 15% across the board. Wow! This is crazy.
On Feb 7, 2025, at 7:01 PM, Miriam Holtzman - mholtzman at ucsd.edu <xxxxxx@lists.healthresearch.org> wrote:
Holy shit. Thank you for sharing that.
Miriam Holtzman (she/her)
Principal Research Analyst
UC San Diego | School of Physical Sciences | Dean's Office
E: xxxxxx@ucsd.edu | P: (224) 619-6631 (Mobile)
Working Location: Thursdays In-Office | NSB | Rm. 5210
On Fri, Feb 7, 2025 at 3:52 PM Amanda Colligan <xxxxxx@usc.edu> wrote:
This seems real?
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-068.html
In accordance with 45 CFR 75 and its accompanying appendices, this Guidance implements and makes publicly available NIH’s updated policy deviating from the negotiated indirect cost rate for new grant awards and existing grant awards, effective as of the date of this Guidance’s issuance. Pursuant to this Supplemental Guidance, there will be a standard indirect rate of 15% across all NIH grants for indirect costs in lieu of a separately negotiated rate for indirect costs in every grant
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