Except that provision only applies to colleges and universities. As I learned when I took a job at the Smithsonian years ago, there is no comparable provision in the UG (it was still OMB Circulars back then, which gives a hint at how long ago that job was) for anybody else – just institutions of higher education. At SI, we got a new IDC rate every year or two, and had to adjust grant budgets accordingly – though we did have some exceptions and a waiver process in place if a project was in its final year, or if making the change would represent a significant detriment to the PI’s ability to carry out the proposed scope of work.
Of course, nobody complained when the IDC rate went down – only when it went up.
Michael Spires, M.A., M.S., CRA
(He/him/his)
Research Development Officer
The Research Office
Oakland University
527 West Wilson Hall
371 Wilson Boulevard
Rochester, MI 48309-4486
(248) 370-2207
Past President, National Organization of Research Development Professionals
The best way to get in touch with me continues to be via email: I am working a hybrid schedule.
Oakland University resides on the ancestral, traditional, and contemporary lands of the Anishinaabe, known as the Three Fires Confederacy, composed of the Ojibwe, Odawa, and Potawatomi. The land was ceded in the 1807 Treaty of Detroit and makes up southeast Michigan.
From: Elliott-Farino, Carolyn E - Carolyn.Elliott-Farino at mainehealth.org (via resadm-l list) <xxxxxx@lists.healthresearch.org>
Sent: Thursday, March 6, 2025 16:34
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] RE: Seeking Guidance - Subaward Management: NPO with Provisional Rate
You probably already know this:
7. Fixed Rates for the Life of the Sponsored Agreement https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/appendix-Appendix%20III%20to%20Part%20200
a. Except as provided in paragraph (c)(1) of § 200.414, Federal agencies must use the negotiated rates in effect at the time of the initial award throughout the life of the Federal award. Award levels for Federal awards may not be adjusted in future years as a result of changes in negotiated rates. “Negotiated rates” per the rate agreement include final, fixed, and predetermined rates and exclude provisional rates. “Life” for the purpose of this subsection means each competitive segment of a project. A competitive segment is a period of years approved by the Federal awarding agency at the time of the Federal award. If negotiated rate agreements do not extend through the life of the Federal award at the time of the initial award, then the negotiated rate for the last year of the Federal award must be extended through the end of the life of the Federal award.
What does their rate agreement say? Does it list increasing rates? I suspect not since they have a provisional rate and provisional rates are excluded from the requirement to use a fixed rate for the life of the sponsored agreement. If their rate agreement listed increasing rates in the out years, they could use these increasing rates, but the awarded amount wouldn’t change. If they charged more in indirects, they would have to accept fewer direct dollars.
I’m not a grant accountant, so if there’s someone who deals with this regularly, I’d love them to chime in.
Carolyn
From: Brakenberry, Melinda Marie - meyer1mm at cmich.edu (via resadm-l list) <xxxxxx@lists.healthresearch.org>
Sent: Thursday, March 6, 2025 3:36 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] Seeking Guidance - Subaward Management: NPO with Provisional Rate
Hello – We have issued a subaward agreement to an entity with a ‘Non-Profit Organization Negotiated Indirect Cost Rate Agreement (NICRA)’ - the entity has a provisional indirect cost rate that is updated annually by their cognizant
Hello –
We have issued a subaward agreement to an entity with a ‘Non-Profit Organization Negotiated Indirect Cost Rate Agreement (NICRA)’ - the entity has a provisional indirect cost rate that is updated annually by their cognizant agency. The budget included in the subaward reflects the provisional indirect cost rate in place at the time the proposal was submitted. We are now receiving invoices with a higher rate, in alignment with the provisional rate that they are currently using to calculate their indirect costs.
We are hoping to better understand how other universities handle this situation – is anyone able to share their process? (eg. amend the subaward; reimburse at the ‘current’ rate without amending the subaward; adjust the invoices and reimburse at the rate included in the executed subaward).
Thank you in advance for your insight and guidance.
Kindly,
Mel
Melinda Brakenberry, MPA, CRA, CFRA
CMU Executive Director for Research & Innovation - Office of Research and Graduate Studies
OoO: Friday, March 7th
Please note: I do not expect a reply from you on evenings or weekends.
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Please keep in mind that responses are copied verbatim to 10,000+ users - - please refrain from "Me Too"s and clicking on reactions to emails. That will keep your email environment clean. Thanks!