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More on Federally Approved Indirect Cost Rates in Developing Federal Grant Proposal Budgets: De Minimus has Arrived

We’ve written about federally approved indirect cost rates before in developing federal grant proposal budgets; I thought there was nothing more to say of this bit of grant writing arcana, but I was wrong.

In general, indirect costs are an agglomeration of “keeping the lights on” costs that are lumped together is a single line item, below the total direct costs in a Federal SF-424A budget form. Since I began writing proposals during Nixon administration,* it was generally necessary for the nonprofit or public agency applicant’s CFO to prepare a “cost allocation plan,” separating the organization’s operating budget into direct costs (e.g., program service staff, client/participant services costs, etc.) and indirect costs (e.g., administrative staff, facility maintenance, etc.).

To claim an indirect cost rate in a federal grant budget, this cost allocation plan must be submitted to the cognizant federal agency, which is the federal department/agency that provides the greatest amount of grant funding to the organization. For example, the cognizant agency for a job training provider would likely be the Department of Labor (DOL), while for an FQHC it would be HRSA.

There’s a Catch-22, however: the organization had to have a federal grant to have a cognizant federal agency to apply to for approval of a cost allocation plan. Thus, non-federal grantees, or ones who never bothered to get an approved cost allocation plan, were basically out of luck regarding indirect costs. There was a workaround: additional line items for administrative costs could broken out. Still, it’s easier to blob a single, indirect-cost line item than it is to include numerous administrative costs, which complicate the budget and narrative while raising uncomfortable questions.

It seems that, while I wasn’t looking, the Feds, and in particular the DOL, has introduced the concept of de minimus into indirect costs. “De minimus” is a Latin expression often used in legal matters to denote something that is too trivial to consider.

We recently completed a DOL proposal for a large nonprofit in a big midwestern city. The client, who we’ve worked for for years, has had lots of federal grants but never applied for an approved indirect cost rate. Since I knew this, I left out indirect costs in the draft budget, putting in a slew of direct cost line items instead. A closer reading of the RFP, however, revealed this nugget:

If you meet the requirements to use the 10 percent de minimis rate as described in 2 CFR 200.414(f), then include a description of the modified total direct costs base.

Apparently the CFR (Code of Federal Regulations) was changed in 2014, allowing a 10% de minimus indirect rate in lieu of an approved rate. Amazing! This old dog has learned a new trick.

Federally approved indirect costs rates can vary from 15% for a small human services nonprofit up to 80% for a university or hospital (think of all the building upkeep, squadrons of deans and hospital administrators, free lunches, etc.). In my experience, however, most Federal agencies will not approve an indirect cost line item more than about 15% for most human services programs, no matter the approved rate. We’ve worked for a large East Cost substance abuse treatment provider that has a Federally approved indirect of 42%, but they never got more than 15% on their federal grants. So the 10% de minimus rate mirrors reality, which is always a surprise in matters relating to the Feds.

* Yes, I’m a geezer.

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