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OMB Uniform Guidance
Key Impacts on CNCS Grantees
6 -
Indirect Costs
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This is the sixth in a series of messages concerning the 2
C.F.R. Part 200 (The Uniform Guidance), and what it means to CNCS grantees. The
regulation section number denotes where in the Uniform Guidance the rule being
discussed in this bulletin is found.
2 C.F.R § 200.414 Indirect (F&A) - Organizations have several options
to recover costs expended in the process of managing federal awards.
• Grantees
receiving direct federal funds may apply for a federally negotiated indirect
cost rate (IDCR) from their cognizant agency.
If grantees already have a final negotiated indirect cost rate that is
within 3 months of expiration, they may request, to their cognizant agency for
indirect costs, a one-time extension of that rate, if they want to continue to
use their current rate on CNCS awards.
Notification of approval of that extension should be provided to the
CNCS Grants Officer, a copy maintained in the recipient’s grant file and
updated in eGrants under the Organization Account Record.
• Subgrantees
receiving only federal pass-through funds may use an indirect cost rate
negotiated by their prime grantor.
• Eligible
grantees may elect to use a flat de minimis rate based on 10% of modified total
direct costs (MTDC). Eligibility rules
are outlined in 2 C.F.R § 200.414 Indirect (F&A).
• Grantees
may charge administrative costs directly as long as those costs are charged
consistent with §200.413.
• States,
local governments and Indian tribes may use approved cost allocation plans.
AmeriCorps State and National grantees have an additional
option:
• AmeriCorps
State and National grantees who do not have an approved federally negotiated
indirect cost rate may continue to utilize the 5% federal/10% match for
administrative expenses pursuant to 2 C.F.R. §2205.414.
Why is This Important?
CNCS will be focused on ensuring that grantees have used the
appropriate method for charging indirect costs and that they have recorded it
accurately. Grantees are accountable for
any and all inaccuracies in recording and applying their IDCR, which may lead
to costs being disallowed later, if costs claimed exceed amounts beyond what the
organization is legally entitled to.
What You Should Do:
All grantees should review the Uniformed Guidance 2 C.F.R § 200.414 Indirect (F&A), as well as obtain training in charging indirect costs to ensure that all of the requirements for the specific method
used have been followed scrupulously. Grantees must record their IDCR in
eGrants under their organization’s account record.
Grantees should ensure that their organization has or is
taking the necessary steps to follow the Uniform Guidance. Adherence to these
standards is important to meet grant requirements and to satisfy any future
audits or monitoring reviews. Do not send documentation to CNCS. When
conducting grant oversight, CNCS staff will request specific documents and
records when necessary.
If you have concerns or questions regarding appropriate
requirements for indirect costs, please send them to
indirectcostrate@cns.gov. Your feedback
and questions will guide us to develop additional information and assistance.
In Service,
Dana
Bourne, Chief Grants Officer Corporation for National and Community Service Grant
Offices Washington, DC and Philadelphia, Pennsylvania
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