If you have received an award from NIFA and would like to claim indirect costs, the information on this page should provide useful information.
I. GENERAL INFORMATION
Are you applying for a National Institute of Food and Agriculture (NIFA) award and are unsure of what rate to budget for indirect costs? While you do not need an approved indirect cost rate to apply for a grant, you should be aware of the options available for indirect cost recovery, presented below. Please understand that you will not be able to draw down indirect cost funds unless you have an approved Negotiated Indirect Cost Rate Agreement (NICRA) from your cognizant agency, or you have elected and are eligible to use the de minimis rate.
To minimize withholds of indirect costs for lack of adequate support we suggest that upon award approval, you inform NIFA Awards Management Division - Administrative Point of Contact (awards@usda.gov) of your selected indirect cost recovery option.
II. LIST OF INDIRECT COSTS RECOVERY OPTIONS
Option 1. Obtain a NICRA with Cognizant Agency
- You do not have a NICRA and want to negotiate a NICRA with the cognizant agency; or
- You would like to request to extend your current negotiated rate for 4 years.
Option 2. Elect to Use De Minimis Rate
- You do not have a current NICRA (or provisional rate) and you do not want to negotiate indirect costs.
Option 3. Waive Indirect Cost Recovery
- You do not want to claim indirect costs.
**What is “Cognizant Agency?”
The cognizant agency for indirect costs is the federal agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals developed under this part on behalf of all federal agencies (2 CFR § 200.19). Unless specifically designated by entity type, the cognizant agency is the agency from whom you receive the most federal funds. If the recipients require assistance identifying their cognizant agency for indirect costs, they may request assistance after NIFA award is made via email at RecipientsICPs@usda.gov.
III. DETAIL GUIDANCE AND INDIRECT COST RECOVERY OPTIONS
**Important Note on Statutory Limitations (CAPS) on Indirect Costs
Applicant recovery of indirect costs (otherwise known as facilities and administration costs) under NIFA awards may be limited by regulation and/or statute. NIFA applicants should identify their program type and follow the indirect cost limitation identified in the request for applications (RFA). Awardees must comply with any indirect cost limitation identified in the award.
**Important Note on Rate Adjustments resulting from NIFA Terms and Conditions (T&C) for Small Business Innovation Research (SBIR) awards.
Applicant recovery of indirect costs under NIFA SBIR awards are subject to the T&C of the award, which specifically identify Independent Research and Development (IR&D) as unallowable expenses. These expenses must be excluded from your indirect cost rate. Awardees must comply with the T&C of any indirect cost limitation identified in the RFA.
1. Obtain a NICRA with Cognizant Agency: Negotiating rates
SCENARIO 1: When NIFA is the Applicants’ Cognizant Federal Agency
Indirect cost negotiation is performed by the U.S. Department of the Interior (DOI) on NIFA’s behalf. If your organization elects to negotiate an indirect cost rate, you must first affirm NIFA is the cognizant agency for indirect costs by sending an email to the dedicated mailbox RecipientsICPs@usda.gov. Once affirmed, the grantee should prepare its Indirect Costs Proposal (ICP) using the DOI Guidance. The DOI templates will simplify and shorten the ICP review process. Please note, until revised DOI templates for commercial entities are available, the non-profit DOI templates are to be used for all entities.
When the ICP is complete, the grantee submits the complete ICP package, including excel and pdf templates, to RecipientsICPs@usda.gov. NIFA will forward the package to DOI for review and negotiation services. Budgeted indirect costs may be withheld pending completion of the indirect cost rate(s) negotiation process. Upon completion of the negotiation process, the grantee will need to contact its grant official to discuss changes to the grant budget resulting from applying negotiated rates.
SCENARIO 2: When NIFA is not the Applicants’ Cognizant Federal Agency
The awardee will be required to provide a current negotiated rate from the cognizant agency in order to recover indirect costs. If you are unable to obtain a negotiated rate from the cognizant agency, NIFA may not reimburse indirect costs and only reimburse allowable direct costs. Violation of cost accounting principles is not permitted when re-budgeting or charging costs to awards. Rather, costs must be consistently charged as either indirect or direct costs. The applicant may submit general indirect cost questions to RecipientsICPs@usda.gov.
Rate Extensions
Grantees with a current NICRA may apply for a one-time extension of the rate for up to four years. The extension will be subject to the cognizant agency’s review and approval. If an extension is granted, the grantee may not negotiate a new rate until the extension period ends. At the end of the extension, the grantee must re-apply for a NICRA. Subsequent one-time extensions (up to four years) are permitted if a negotiation is completed between each extension request.
Only final and predetermined rates may be eligible for consideration of rate extensions. If NIFA is your cognizant agency, please send your requests for extension to NIFA at RecipientsICPs@usda.gov and indicate the rate and fiscal periods to be covered by the rate extension. You might be requested to provide additional information so that NIFA can assess approval of extensions. If NIFA is not your cognizant agency, refer to your cognizant agency website for guidance and approval.
2. Elect to Use the De Minimis Rate
Note: OMB has updated the 2 CFR allowing an indirect cost de minimis rate increase from 10 percent to 15 percent effective October 1, 2024.
Any entity that does not have a current NICRA (including provisional) and has received less than $35 million in direct federal funding for the fiscal year requested, may elect to charge a de minimis rate of 15% of modified total direct costs (MTDC), as defined in 2 CFR 200.414(f). No documentation is required to justify the de minimis indirect cost rate. As described in § 200.403, costs must be consistently charged as either indirect or direct costs, but may not be double charged or inconsistently charged as both. Once elected, the rate must be used consistently for all Federal awards until the entity chooses to negotiate for a rate, which the entity may request at any time. The proper use and application of the de minimis rate is the responsibility of the award recipient. The awarding federal agency may perform a financial monitoring review to ensure compliance with 2 CFR Part 200.
Election of the de minimis rate does not require approval of the cognizant agency for indirect costs. A review by the cognizant agency for indirect costs is only required when a negotiated rate is requested. Please note, the prime awardee is responsible for determining indirect costs for their sub-recipients or pass through sub-awardees.
The de minimis rate will be applied to Modified Total Direct Cost (MTDC). This MTDC base includes all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $50,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $50,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs, and with the approval of the cognizant agency for indirect costs.
3. Waive Indirect Cost Recovery
An applicant may elect not to request recovery of indirect costs. If so, the applicant should write "None Requested" in the space allotted for item H of the budget sheet.
Additional Resources
** Disclaimer: The contents of this page do not have the force and effect of law and are not meant to bind the public in any way. The information is intended only to provide clarity to NIFA award recipients regarding existing requirements under the law or agency policies.