Published April 28, 2026, via Research News
On April 20, 2026, NIH announced an update to their implementation of uniform administrative requirements for federal financial assistance.
NIH states that, although it previously incorporated updates from the 2024 revisions to 2 CFR Part 200 (Uniform Guidance), the FY 2026 appropriations law requires that the provisions relating to indirect costs in 45 CFR Part 75 continue to apply to NIH awards. Accordingly, NIH indicates it “will not apply updated thresholds outlined within 2 CFR Part 200, at this time.”
As a result, NIH rescinds the following Uniform Guidance flexibilities included in prior guidance (NOT-OD-25-059):
- The updated Modified Total Direct Cost (MTDC) definition (including the $50,000 subaward threshold); and
- The updated 15% de minimis indirect cost rate.
While the notice does not restate specific thresholds, NIH’s direction to apply 45 CFR Part 75 reflects a return to the prior framework for indirect cost calculations, including:
- MTDC including up to the first $25,000 of each subaward; and
- A 10% de minimis indirect cost rate for eligible entities without a negotiated rate.
Note: the MTDC definition does not include the threshold for equipment. That threshold is in the equipment definition, and the prior guidance is, therefore, still in place:
- 2 CFR 200.313 (e) – Equipment: NIH recognizes the updated threshold value for equipment, increasing from $5,000 to $10,000.
Note that WashU has not yet adopted the $10,000 equipment threshold.
All proposals from WashU to NIH should continue to utilize the following:
- MTDC including up to the first $25,000 of each subaward
- A 10% de minimis indirect cost rate for eligible entities without a negotiated rate.
- $5,000 threshold for equipment
If you have any questions about this material, please contact Krystina Gross or Teri Medley.