Congress has directed NIH and the Department of Defense to maintain negotiated indirect cost rates and restrict the use of rate caps within recent appropriations legislation. The update may affect grant funding, reimbursement expectations, and agreement terms. Organizations should understand how timing and regulatory alignment influence existing and future awards.
Topics: Accounting System Compliance, DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
Congress and recent appropriations legislation have restricted federal agencies from applying indirect cost rate caps on grants, reinforcing the use of negotiated rates. The change affects DOE and other agencies and may require organizations to review award terms, reimbursement eligibility, and timing considerations tied to indirect cost recovery.
Topics: Accounting System Compliance, DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
Department of Defense class deviations are implementing the Revolutionary FAR Overhaul across multiple FAR and DFARS parts, with effective dates beginning as early as February 1, 2026. These changes affect clause structure, regulatory language, and timing considerations, requiring contractors to closely evaluate solicitations, flowdowns, and contract terms to maintain alignment with updated requirements.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)
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Government contractors will see another significant change to the acquisition threshold under the FY 2026 National Defense Authorization Act. The Truthful Cost or Pricing Data threshold is increasing to $10 million, creating new considerations for proposals, negotiations, and contract modifications. Multiple threshold updates within a short period have introduced added complexity around timing, clause language, and award dates. Understanding how these changes interact with existing contracts is essential for maintaining consistency and avoiding unnecessary compliance risk.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance
We knew this was coming based on the June 30, 2025, PF 2025-38 (FAL 2025-05) Implementation of Indirect and Fringe Benefits Cost Reimbursement Limits on Financial Assistance Awards guidance to Granting officers. However, we believed the May 15, 2025, preliminary injunction issued by the U.S. District Court for the District of Massachusetts in the case of Association of American Universities et al. v. U.S. Department of Energy would slow down DOE‘s implementation of the cap on indirect cost recovery for more than just Institutions of Higher Education (IHEs). Sadly, that is not the case.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
The de minimis rate is an indirect rate that can be elected by Non-federal entities (State, local government, Indian Tribe, Institution of Higher Education or non-profit) that do not have a current negotiated indirect cost rate agreement (NICRA). The de minimis rate is addressed in 2 Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, specifically 200.414(f).
Topics: Accounting System Compliance, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)
On May 8, 2025, Department of Energy (DOE) issued three new policy flashes limiting the indirect costs on DOE grants to state and local government, for non-profit organizations and for-profit companies. DOE previously limited indirect costs for colleges and universities (i.e., Institutes of Higher Education) in its April 11, 2025 policy action.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
President Trump issued several executive orders addressing tariffs. American First Trade Policy dated January 20, 2025 and Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment dated April 9, 2025. In addition, he has also issued a 90-day pause to some countries and is planning to reduce tariffs on certain industries such as US auto tariffs (see Amendments to Adjusting Imports of Automobiles and Automobile Parts into the United States dated April 29, 2025). It is clear that tariffs are impacting the supply chain and government contractors.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Federal Acquisition Regulation (FAR), Manufacturing Operations Consulting
The Government Accounting Office (GAO) issued a Report, Recent Guidance Could Enhance Subaward Oversight to the Senate dated March 26, 2025 (GAO-25-107315), on its review of subaward oversight based on requirements in 2 CFR 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Grants. While prime recipients have responsibility over subawards, federal agencies are required to ensure recipients carry out oversight responsibilities.
Topics: Accounting System Compliance, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
On April 11, 2025, the Department of Energy (DOE) announced a new policy action to limit indirect costs of DOE research funding to Institutes of Higher Education (IHE) to 15%. DOE projects this change to generate over $405 million in annual savings. As expected, a judge has issued a Temporary Restraining Order (TRO) on this policy. This comes on the heels of the National Institute of Health (NIH) issuing Supplemental Guidance to the 2023 NIH Grants Policy Statement: Indirect Costs dated February 7, 2025, limiting indirect costs on current and future grants to 15%. A Temporary Restraining Order (TRO) is still outstanding on the NIH policy.
Topics: Accounting System Compliance, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)