Office of the Comptroller
Financial Compliance

National Institutes of Health Indirect Cost Rate FAQs

NIH recently issued Notice NOT‑OD‑26‑072, which has generated questions about whether NIH indirect cost (F&A) rules have changed again—and whether there is any adverse impact for Drexel investigators.

To support the Drexel research community, the Office of the Comptroller and the Office of Research & Innovation have prepared the following FAQs to clarify what has not changed, what has reverted, and how NIH awards should be budgeted going forward. 

What You Need to Know

The 15% NIH indirect cost cap is NOT in effect.

The $50,000 subaward MTDC threshold does NOT apply to NIH. The $25,000 limit remains.

Drexel’s federally negotiated F&A rate continues to apply to NIH awards.

NIH has reverted to its prior indirect cost framework. Budget NIH awards accordingly.

 

Frequently Asked Questions

Last updated: April 2026

For new NIH proposals:

  • Use Drexel’s negotiated F&A rate.
  • Apply the $25,000 MTDC subaward cap.
  • Use the 10% de minimis rate only for subrecipients without negotiated rates.
  • Do not use a $50,000 MTDC base or a 15% cap.

For active NIH awards:

  • Expect possible rebudgeting guidance from ORS or Post‑Award, if applicable.
  • No retroactive benefit applies from NIH’s short‑lived 2025 flexibilities.

For new NIH proposals:

  • Use Drexel’s negotiated F&A rate.
  • Apply the $25,000 MTDC subaward cap.
  • Use the 10% de minimis rate only for subrecipients without negotiated rates.
  • Do not use a $50,000 MTDC base or a 15% cap.

For active NIH awards:

  • Expect possible rebudgeting guidance from ORS or Post‑Award, if applicable.
  • No retroactive benefit applies from NIH’s short‑lived 2025 flexibilities.

For new NIH proposals:

  • Use Drexel’s negotiated F&A rate.
  • Apply the $25,000 MTDC subaward cap.
  • Use the 10% de minimis rate only for subrecipients without negotiated rates.
  • Do not use a $50,000 MTDC base or a 15% cap.

For active NIH awards:

  • Expect possible rebudgeting guidance from ORS or Post‑Award, if applicable.
  • No retroactive benefit applies from NIH’s short‑lived 2025 flexibilities.

No.

  • Drexel’s federally negotiated F&A rate remains unchanged.
  • There is no new NIH‑wide cap on Drexel’s indirect cost recovery.
  • There is no impact on effort reporting, cost allowability, or audit standards.

The March 2026 Comptroller guidance reflected government‑wide updates to the Uniform Guidance. NIH, however, is a specific statutory exception due to long‑standing Congressional appropriations language.

  • The $25,000 MTDC subaward cap continues to apply for NIH awards only.
  • Other federal sponsors may still follow updated Uniform Guidance thresholds, unless otherwise restricted.

Researchers should continue to follow sponsor‑specific guidance, with ORS and Post‑Award assisting as needed.

The March 2026 Comptroller guidance reflected government‑wide updates to the Uniform Guidance. NIH, however, is a specific statutory exception due to long‑standing Congressional appropriations language.

  • The $25,000 MTDC subaward cap continues to apply for NIH awards only.
  • Other federal sponsors may still follow updated Uniform Guidance thresholds, unless otherwise restricted.

Researchers should continue to follow sponsor‑specific guidance, with ORS and Post‑Award assisting as needed.