Examples
Worked examples
- Is an instance
A community-based research non-profit charges the 10 percent de minimis rate on its NIH grant, applied to MTDC (NIH reverted to 10 percent in April 2026, while the government-wide 2 CFR 200.414(f) ceiling is 15 percent).
- Is an instance
A new university research office uses the de minimis rate during its first three years while preparing a full F&A rate negotiation.
Counter-examples
Looks similar, but isn't
- Not an instance
An institution with a current negotiated 55 percent F&A rate cannot elect the de minimis rate at all.
- Not an instance
A flat 10 percent administrative fee charged by a foundation outside US federal rules is not the de minimis rate.
Editorial commentary
Under Uniform Guidance 2 CFR 200.414(f), recipients that have never received a negotiated indirect cost rate may elect the de minimis rate on US federal awards, applied to Modified Total Direct Costs (MTDC), indefinitely or until a negotiated rate is established. The government-wide ceiling was raised from 10 percent to 15 percent of MTDC by OMB’s April 2024 revision to the Uniform Guidance, effective for awards issued on or after October 1, 2024. No formal election or federal approval is required to use it.
NIH-specific reversion: Notice NOT-OD-26-072
Despite the “NIH” in this term’s common usage, the 15 percent figure did not stay NIH’s own operative rate for long. NIH issued Notice NOT-OD-26-072 on April 20, 2026, reverting the de minimis indirect cost rate on its own awards back to 10 percent, and reverting the MTDC subaward threshold back to $25,000 (from the $50,000 figure the 2024 Uniform Guidance revision had introduced). NIH’s stated basis is that the FY2026 appropriations law requires the indirect-cost provisions of 45 CFR Part 75 to continue applying to NIH awards, effectively overriding the general 2024 Uniform Guidance update for NIH specifically. The notice explicitly left the equipment capitalisation threshold at $10,000 unchanged. The practical result is a split: the government-wide de minimis ceiling under 2 CFR 200.414(f) remains 15 percent, but an institution submitting to NIH specifically should use 10 percent unless and until NIH issues further guidance. Always confirm which figure a specific funding opportunity or notice of award actually cites — other federal agencies were not affected by NOT-OD-26-072 and remain at the 15 percent, $50,000 figures.
Who uses it, and its limits
The de minimis rate is used most commonly by small non-profits, community-based organisations, and new academic spin-outs or centres that have not yet built the cost-accounting infrastructure to support a full negotiated F&A rate proposal. An institution that already holds a current negotiated rate cannot elect the de minimis rate instead — 2 CFR 200.332(a) specifically bars a pass-through entity from requiring a subrecipient with an existing negotiated rate to use the de minimis rate in its place.
References
- US Office of Management and Budget, Uniform Guidance 2 CFR 200.414(f) (as revised April 2024, effective October 1, 2024).
- NIH Notice NOT-OD-26-072, grants.nih.gov, issued April 20, 2026 (primary NIH page returned an access error on direct fetch this session; content corroborated via COGR’s published commentary and multiple institutional sponsored-programs offices’ summaries, e.g. Harvard OSP, Princeton ORPA).
Also known as
10 percent de minimis · De minimis indirect rate
Machine-readable encodings
Use in your systems
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