Update – NIH Implementation of Uniform Administrative Requirements for Federal Financial Assistance Notice Number: NOT-OD-26-072

NIH has issued Notice NOT‑OD‑26‑072, clarifying its implementation of Uniform Guidance requirements related to indirect costs. The notice rescinds recent NIH flexibilities and confirms a return to the indirect cost framework that has governed NIH awards since FY 2017.

NIH explains that FY 2026 appropriations language requires the agency to apply indirect cost provisions “to the same extent and in the same manner” as was done in FY 2017, when NIH operated under 45 CFR Part 75. As a result, NIH will not implement the updated indirect cost thresholds included in the 2024 revisions to 2 CFR Part 200 at this time, despite having previously adopted certain Uniform Guidance updates. Instead, the indirect cost provisions of 45 CFR Part 75 will continue to apply to NIH awards.

Please review the key updates below and apply them to all affected NIH proposals, budget justifications, and award setups.

Key Takeaways:

Subaward MTDC Threshold Has Reverted to $25,000

NIH will not apply the expanded $50,000 Modified Total Direct Cost (MTDC) threshold.  Budgets should apply indirect costs on only the first $25,000 of each subaward for NIH proposals and awards.

• MTDC includes only the first $25,000 of each subaward
• Amounts in excess of $25,000 are excluded from the MTDC base
• This applies regardless of the total subaward amount

15% Indirect Cost Rate Does Not Apply to NIH

NIH has rescinded the 15% indirect cost rate that was briefly adopted under revised Uniform Guidance.

• Institutions with a Negotiated Indirect Cost Rate Agreement (NICRA) must apply their full negotiated rate
• Entities without a NICRA may continue to use the 10% de minimis rate
• NIH is not imposing an indirect cost cap

What Has Not Changed

• The equipment capitalization threshold of $10,000 remains in effect
• NIH continues to recognize updated equipment definitions under Uniform Guidance

Summary Table

Please ensure these policies are consistently applied across NIH proposal development, budget reviews and justifications, and award setup and post‑award administration.

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-26-072.html