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Indirect Cost Guidance 

Published February 11, 2025, via Research News

Dear Research Admin Community,

We recognize that the guidance coming out of the federal government has been confusing and rapidly changing. The recent guidance (NOT-OD-25-068) from the NIH cutting F&A to 15% has prompted multiple lawsuits. As of midnight, February 10th, a nationwide temporary restraining order (TRO) has been issued by the court. At this time, please adhere to the following guidance.

1. Proposal Submissions:

  • Proposal submission practices have not changed. We will continue to submit proposals at the negotiated indirect cost rate. Do not submit proposals using the 15% rate.

2. No-Cost Extensions (NCEs):

  • Principal Investigators (PIs) should not assume that first time no-cost extension requests will be approved.

3. New Awards:

  • If we receive new awards or flow-through awards with the 15% rate:
    • They will be placed on hold until the indirect cost rate is resolved.
    • PIs must not charge existing awards for costs associated with a project that is on hold pending resolution of the IDC rate.
  • Project activations for new NIH awards will not be processed by SPA until the NoA is received at the negotiated IDC rate. This does not apply to NIH funding mechanisms with IDC rates normally below our negotiated rate such as training grants.

4. Reimbursement:

  • Sponsored Projects Accounting (SPA) will draw down funds from the NIH at the negotiated IDC rate.
  • SPA will not draw down funds from the NIH at the 15% rate. 

5. Rebudgeting Existing Awards:

  • Do not re-budget costs from indirect to direct categories.

 6. Invoicing:  

  • We have seen an increase in requests from departments to send invoices on agreements that are not fully executed. SPA can NOT send invoices for awards that are not fully negotiated and signed. 

Please note that ongoing litigation and further communications from the NIH may result in changes to these instructions. We will keep you updated with any new information as soon as it becomes available.

If you have any questions or need further clarification, please do not hesitate to reach out via the RA Teams network.

Sincerely,

Mark E. Lowe, MD, PhD
Vice Chancellor for Research
Associate Dean for Research, School of Medicine
Harvey R. Colten Professor of Pediatric Science

Richard Stanton
Vice Chancellor of Administration and Finance
Washington University School of Medicine