Examples
Worked examples
- Is an instance
A university's on-campus research F&A rate is 62 percent of MTDC, effective for the fiscal years 2023 to 2027.
- Is an instance
An off-campus rate of 26 percent applies to projects conducted at a partner facility for more than 50 percent of the budget period.
- Is an instance
A community-based nonprofit with no history of direct federal awards elects the 15 percent de minimis indirect cost rate under 2 CFR 200.414(f) rather than negotiating its own rate.
Counter-examples
Looks similar, but isn't
- Not an instance
A Horizon Europe flat 25 percent rate is not an F&A rate.
- Not an instance
A foundation's 10 percent cap on indirect is a programmatic payment limit, not the institution's negotiated indirect cost rate.
- Not an instance
NIH's 2025 flat 15 percent indirect-cost policy for all institutions, since enjoined by federal courts, was a payment cap imposed on top of existing rates — not a renegotiation of each institution's own F&A rate.
Editorial commentary
The indirect cost rate — called the Facilities & Administrative (F&A) rate in US federal terminology — is the percentage applied to a defined direct-cost base to recover an institution’s overhead costs: the facilities, administration, and other costs that support a sponsored project but cannot be charged to it directly (building depreciation, utilities, library services, general and departmental administration, sponsored-projects administration). It is the counterpart to direct costs, which are specifically identifiable to one project.
How the rate is negotiated
F&A rates are negotiated periodically between an institution and its cognizant federal agency — normally the US Department of Health and Human Services (HHS) or the Department of the Navy’s Office of Naval Research (ONR), assigned per institution based on which agency has historically provided the larger share of its federal funding (HHS is cognizant for the large majority of US institutions of higher education). The institution submits a detailed F&A rate proposal documenting allowable indirect cost categories (depreciation, operations and maintenance, library, general administration, departmental administration, sponsored-projects administration, student services) under 2 CFR Part 200, Appendix III (indirect cost rate determination for institutions of higher education). Research universities typically negotiate on-campus F&A rates between 50 and 70 percent of Modified Total Direct Cost (MTDC); off-campus rates — applied when a majority of a project’s work happens away from institution-owned facilities — are lower, often 25 to 30 percent. Once agreed, the negotiated rate must be accepted by every federal agency awarding to that institution (2 CFR 200.414(c)); a sponsor may still apply a lower programmatic payment cap, but that is a separate constraint from the negotiated rate itself, which remains the ceiling for what could be recovered.
Negotiated rate vs. the de minimis rate
Not every organization has, or wants, a negotiated rate. Under 2 CFR 200.414(f), a recipient or subrecipient that does not currently hold a federally negotiated indirect cost rate may instead elect a de minimis rate — currently up to 15 percent of MTDC government-wide, following OMB’s April 2024 Uniform Guidance revision (effective for awards issued on or after October 1, 2024; the rate had previously been 10 percent). See de minimis rate for the full mechanics: no formal proposal or agency approval is required, and once elected the rate applies to all of that recipient’s federal awards. The two mechanisms answer the same question — how is overhead recovered — differently. A negotiated rate reflects one institution’s actual, documented cost structure; a de minimis rate is a flat substitute for organizations without the cost-accounting history or infrastructure to negotiate one, typically smaller nonprofits, community organizations, and newer research-performing entities.
Individual federal agencies can diverge from the government-wide de minimis figure where a separate statute or long-standing appropriations rider requires it. NIH is the clearest current example: an appropriations provision keeps NIH’s indirect-cost rules tied to 45 CFR Part 75 rather than the general 2 CFR 200 figures, and NIH’s April 2026 notice (NOT-OD-26-072) reverted its own de minimis rate back to the longstanding 10 percent of MTDC, rescinding a brief 2025 alignment with the 15 percent government-wide rate — see CASRAI’s coverage of that notice. That is a separate action from NIH’s earlier, since-enjoined attempt to cap negotiated F&A rates at a flat 15 percent for all institutions — see NIH’s 15% indirect cost cap: current status for that specific, contested policy history. Because agency-specific figures move, always confirm the current rate against the awarding agency’s own current guidance rather than assuming the 2 CFR 200.414(f) government-wide default applies uniformly.
Related CASRAI vocabulary
- Indirect costs (overheads) — the broader concept this rate recovers
- MTDC (Modified Total Direct Cost) — the base the rate is applied to
- Indirect cost recovery — the resulting institutional revenue
- Cost Accounting Standards Disclosure Statement (DS-2) — documents the cost-accounting practices behind a negotiated rate proposal
- Uniform Guidance (2 CFR 200) — the governing federal cost-principles framework
- How to Calculate Indirect Costs (F&A) vs. Direct Costs — a worked walkthrough applying a negotiated or de minimis rate to an actual budget
- NICRA: Negotiated Indirect Cost Rate Agreements Explained — how the negotiated rate agreement described above is actually reached and documented
References
- US Office of Management and Budget, Uniform Guidance, 2 CFR Part 200, Subpart E (Cost Principles) and Appendix III (Indirect Cost Rate Determination for Institutions of Higher Education); 2 CFR 200.414(c) and 200.414(f) specifically.
- Council on Governmental Relations (COGR) F&A guidance; NIH Notice NOT-OD-26-072 (April 20, 2026).
When this last changed, and how you find out next time
The 15 percent government-wide de minimis rate above is current as of October 1, 2024. It is not permanent: OMB revised 2 CFR 200 on April 22, 2024, published in the Federal Register at 89 FR 30046, and the 15 percent figure above is the post-revision one — it replaced a 10 percent government-wide default.
OMB publishes every change to the Uniform Guidance in the Federal Register, and the Federal Register is one of the sources Regulatory Radar checks every day — so 2 CFR 200 is one of the few subjects where CASRAI reads the primary publication venue itself rather than waiting for somebody’s summary. It does not watch the NIH Guide, and it does not watch private accreditors — which matters directly here, since NIH sets its own de minimis figure separately under 45 CFR Part 75 and reverted to 10 percent by an April 2026 NIH notice, not by a further Uniform Guidance revision.
Ask CASRAI what 2 CFR 200 currently requires for electing the de minimis indirect cost rate as a first-time federal awardee — it answers from an indexed corpus it re-checks daily and cites the passage it used, so you can open the source and check it. Two questions a day are free while you are signed out, no account and no card. Regulatory Radar is $29 a month for 150 a day, a subscriber dashboard, API keys and MCP access. Everything CASRAI publishes, including this page, stays free to read.
Frequently asked questions
Who negotiates an institution’s F&A (indirect cost) rate?
The institution’s cognizant federal agency — normally HHS, or the Department of the Navy’s Office of Naval Research for a smaller group of institutions — based on which agency provides the larger share of the institution’s federal funding.
What is the difference between on-campus and off-campus F&A rates?
On-campus rates for research universities typically run 50 to 70 percent of Modified Total Direct Cost (MTDC). Off-campus rates, applied when most of a project’s work happens away from institution-owned facilities, are lower — often 25 to 30 percent.
What is the de minimis rate, and who can use it instead of a negotiated F&A rate?
Under 2 CFR 200.414(f), a recipient or subrecipient that does not currently hold a federally negotiated indirect cost rate may elect a flat de minimis rate — up to 15 percent of MTDC government-wide since October 1, 2024 — with no formal proposal or agency approval required.
Can a sponsor pay less than an institution’s negotiated F&A rate?
Yes. A sponsor may apply a lower programmatic payment cap, but that is a separate constraint from the negotiated rate itself, which remains the ceiling for what could be recovered.
Does NIH use the same de minimis rate as other federal agencies?
No. NIH ties its indirect-cost rules to 45 CFR Part 75 rather than the general 2 CFR 200 figure, and NIH Notice NOT-OD-26-072 (April 2026) reverted NIH’s own de minimis rate to 10 percent of MTDC after a brief 2025 alignment with the 15 percent government-wide rate.
Also known as
F&A · Facilities and Administrative rate · Negotiated indirect rate · Federally negotiated rate · Indirect Cost Rate · Indirect rate · IDC rate · Overhead rate
Machine-readable encodings
Use in your systems
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