Last April, the Office of Management and Budget announced that grant recipients and subrecipients that adopt the “de minimis” indirect cost rate could charge up to 15%, previously 10%, of their modified total direct costs (MTDC) incurred on federal awards. This is an allowance for the indirect costs attributable to facilities and administrative support of awards.

This February, the National Institutes of Health, announced that, despite the fact that a grant recipient might have a negotiated indirect cost rate agreement (NICRA) with the federal government, the recipient could only charge 15% of their MTDC as an indirect cost allowance. NIH relied on an obscure provision of OMB’s Uniform Guidance (2 CFR 200.414(c)) that permits a federal agency to deviate from honoring a negotiated rate, under certain circumstances. Not surprisingly, recipients responded with outrage — and lawsuits.

Two unconnected developments? … coincidence? … or part of a conscious federal effort to corral one of the most misunderstood policies associated with federal award administration? There’s long history showing a federal desire to restrict grantee indirect cost recovery. That history and the recent developments suggest that now is a good time for awardees to look closely at their cost-charging practices and decide how to position them for what might be significant challenges ahead.

This webinar will help you do that. You’ll learn about:

• Longstanding fair “cost sharing” policies
• Indirect cost recovery controversies
  • College and university administrative cost caps
  • Charges for state and local government taxes
  • Nonprofit organization lobbying costs
  • The burden of cognizance
    • Labor-intensive rate methods
• Conflating indirect cost and administrative cost
  • Direct cost = “good”
  • Indirect cost = “bad”
• Statutory cost limitations
• OMB Cost Principles: 2 CFR 200, Subpart E
• Direct versus indirect — the real definitions
• Fashioning a defensible “cost policy statement”
  • Cost categories that lend themselves to direct charging
• Cost allocation plans and rate proposals
• How the “de minimis rate” is supposed to work

Hand-out Materials:

Attendees will receive presentation slides as well as access to background materials.

Allowable Charges

The costs of webinars sponsored by Federal Fund Management Advisor™ are allowable charges to your federal grants and subgrants. The cost principles issued by OMB under its uniform guidance (and applicable to all types of awardees) state, “The cost of training and education for employee development is allowable” (2 CFR 200.472).

Attend this Live Webinar and Earn up to 2.4 CPE Credits