What happened?
NIH issued a policy update that essentially walks back parts of the 2024 Uniform Guidance changes related to indirect costs (F&A).
The biggest reversals are:
A. Subaward F&A threshold goes back to $25,000
NIH is rescinding the newer $50,000 MTDC subaward threshold and reverting to the long-standing rule:
- NIH F&A can only be charged on the first $25,000 of each subaward
- Not the first $50,000
This is a major operational change because many institutions had already begun preparing for or implementing the $50K threshold.
B. De minimis indirect cost rate goes back to 10%
The Uniform Guidance update increased the de minimis indirect cost rate from:
- 10% → 15%
NIH is not adopting that increase at this time.
So NIH subrecipients without a negotiated indirect cost rate may only use:
- 10% de minimis
- NOT 15%
Why did NIH reverse course?
NIH cites:
- FY2026 appropriations language
- Legal and regulatory constraints
- Requirement to maintain prior indirect cost methodologies
In simple terms:
Congress restricted NIH from fully adopting some of the broader Uniform Guidance flexibility changes.
What DOES remain changed?
One important update still stands:
Equipment threshold remains $10,000
The capitalization/equipment threshold increase from:
- $5,000 → $10,000
still applies.
That means equipment purchases at or above $10,000 can still be excluded from MTDC calculations for NIH.
Learn More:
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-26-072.html
Attain Partners article/explanation: NIH Rescinds the New Threshold for Subawards and the 15% De Minimis Rate – Attain Partners