Why this changes a decision
A finance policy that says ‘federal indirect rate’ as though one default controls every award can now produce the wrong budget. The responsible question is not which headline rate is current. It is which provision governs this recipient, this agency, this award, and this period of performance.
Fact one: the government-wide ceiling changed
Under 2 CFR 200.414(f), a recipient or subrecipient without a current negotiated indirect-cost rate may elect a de minimis rate up to 15% of modified total direct costs. OMB’s 2024 revision also raised the portion of each subaward included in the MTDC base from $25,000 to $50,000. The government-wide effective date was October 1, 2024, although an agency could elect to apply the revision to earlier awards. Evidence vintage: OMB final guidance published April 22, 2024; effective October 1, 2024; reviewed August 3, 2026.
Fact two: NIH did not keep those indirect-cost updates
NIH Notice NOT-OD-26-072, released April 20, 2026, says the FY2026 appropriations law requires NIH’s indirect-cost provisions to continue under 45 CFR Part 75. NIH therefore rescinded its adoption of the revised MTDC definition and 2 CFR 200.414(f) flexibility ‘at this time.’ The March 2026 NIH Grants Policy Statement states a 10% MTDC de minimis rate for recipients without a current negotiated rate. Evidence vintage: NIH notice released April 20, 2026 and March 2026 policy statement; reviewed August 3, 2026.
The connection
The difference is not a general choice between 10% and 15%. The government-wide rule establishes one path; NIH’s current appropriations-driven implementation establishes another for NIH awards. Negotiated rates, program-specific limits, pass-through terms, and the actual notice of award remain separate questions.
That makes a mixed-agency portfolio a line-by-line governance problem. The same organization can have different indirect-cost treatment across awards, but it should never infer the correct treatment from agency name alone when the award and incorporated terms are available.
What this changes
For each federal pursuit and active award, record the governing authority, rate path, MTDC definition, incorporated agency policy, negotiated-rate status, and effective period. Recalculate the budget only after those fields agree. If NIH is in the portfolio, separate it from the government-wide default rather than burying the difference inside one overhead assumption.
What the evidence does not say
The NIH notice does not abolish negotiated indirect-cost rates, and a de minimis rate is neither a universal entitlement nor a universal cap. The OMB revision permits an eligible entity to elect up to 15%; it does not make every award pay 15%. NIH’s notice also says the updated thresholds will not apply ‘at this time,’ so durability beyond the current statutory and policy setting should not be assumed.