Federally negotiated indirect costs rates generally will be applied on all proposals unless:
- The indirect costs rate is limited by federal statute or regulation.
- The funding agency has a special rate pre-approved by SPARCS, also known as Indirect Cost Waivers.
- The sponsor is a non-profit organization with a published, consistently applied policy limiting indirect costs.
All other exceptions to the university’s negotiated rates require prior approval from the college research office (CRO) and SPARCS. Approved exceptions may result in a financial penalty to the requesting college.
Please note that any subcontractors also must adhere to the sponsor-specific restrictions on indirect costs that NC State honors.
Predetermined Rates to be Applied to Projects Proposed from 07/01/2016 to 06/30/2020
|Location||Research||Instruction||OSA** and Public Service|
**OSA = Other Sponsored Activities
Above Rates are Applied to the Modified Total Direct Costs (MTDC Base).
Uniform Guidance (Appendix III, C.7) advises that rates should be fixed for the life of an agreement.
Determining the Type of Project You Are Proposing
|Research:||Investigation or experimentation aimed at the discovery of new knowledge or that builds upon existing knowledge. The creation of new knowledge and/or the use of existing knowledge in a new and creative way resulting in new concepts, methodologies and understandings.|
|Instruction:||The dissemination of knowledge or information through teaching and non-research training activities. These activities include developing or compiling course and curriculum materials/programs.|
|Other Sponsored Activities:||The dissemination of known knowledge or processes. Service performed for the benefit of the public. A program that geographically extends the resources of the institution to entities or persons otherwise unable to take advantage of such resources.|
Sponsored agreements will not be subject to more than one indirect costs rate. If more than 50% of a project is performed off-campus, the off-campus rate will apply to the entire project. Similarly, if your project contains components from more than one classification (i.e., research and instruction) then only the rate of the most significant component will apply.
Common Bases Used to Calculate Indirect Costs
Modified Total Direct Costs (MTDC)
MTDC is defined in the Uniform Guidance (§200.68) as all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment greater than $5,000, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $25,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs — and only with the approval of the sponsor.
Sample MTDC Budget
Total Direct Costs (TDC)
TDC is when the indirect costs are charged on all costs — no exclusions or exceptions.
Sample TDC Budget
Total Federal Funds Awarded (TFFA)
TFFA is when the indirect costs are considered to be on the full amount of the award, but it is actually calculated using TDC. For example, if the sponsor allows 22% TFFA, 28.20513% of the TDC would be used to arrive at 22% TFFA. If the sponsor allows 30% TFFA, 42.857% TDC would be used to arrive at 30% TFFA.
New RFA’s coming out of USDA-NIFA state the following: “Pursuant to section 720 of the general provisions to the consolidates and continuing appropriations act, 2012 (Pub. L. 112-55), indirect costs are limited to 30% of the Total Federal Funds provided under each award. Therefore, when preparing budgets, applicants should limit their requests for recovery of indirect costs to the lesser of their institution’s official negotiated indirect cost rate or the equivalent of 30% of TFFA.”
- 30% of TFFA is equivalent to 42.857% TDC.
- To figure out which rate to charge, you will need to calculate both and use the lesser of the two. If there are no exclusions (i.e., equipment, tuition, subcontract amounts greater than $25K), then TFFA is almost always going to be less than the university’s official negotiated indirect costs rate. But if you have significant exclusions in your budget, it is likely that the university’s official indirect costs rate will be less. The only way to know is to calculate the budget both ways and use the lesser amount.
Under no circumstance can more indirect costs be requested than what would be allowed using the federally negotiated rates identified above. For example, if you are using the 22% on Total Federal Funds Awarded (TFFA) as required by the USDA-NRICGP, it is not uncommon for the total indirect costs request to be in excess of what the full, federally negotiated rate and base would produce if applied. This can happen because, under the federally negotiated rate, cost elements such as equipment, tuition and subcontractor costs in excess of $25,000 are excluded from the base prior to applying the rate. In the USDA example, nothing is excluded — which often results in a substantially higher base. For proposals being submitted to federal agencies, it is crucial to calculate the indirect costs both using the sponsor’s indirect costs rate as well as our federally negotiated rate to ensure we are not charging excess indirect costs. The lesser of the two amounts for indirect costs should be used.
Sample TFFA Budget
Under-recovery of Indirect Costs as Cost Share
Foregone or under-recovery of indirect costs on the sponsored portion of a project, as well as indirect costs associated with the university contribution, can generally be claimed as cost-sharing. If indirect costs are defined as unallowable by the sponsor, then such costs are also unallowable as cost-share; however, unallowability must be determined by statutory regulations for all federal agencies. Under-recovery of facilities and administrative costs may only be used as cost-sharing if facilities and administrative costs are considered unreimbursed rather than unallowable costs. Please call SPARCS at 919.515.2444 or email firstname.lastname@example.org if you would like assistance negotiating indirect costs allowability with sponsors.
More About Cost Sharing