NSF proposals and IDC rate; NIH foreign subawards
Dear colleagues,
NSF Proposals and IDC Rate
On Friday, May 2, NSF issued a policy notice stating that NSF is adopting a 15% indirect cost (IDC) rate for grants and cooperative agreements. Several organizations filed a joint lawsuit on Monday, May 5 seeking to halt a cut to the indirect cost rate on NSF awards. Until a decision comes from the courts, CU Boulder will continue to submit NSF proposals according to our negotiated indirect cost rate agreement as long as:
- The solicitation does not specifically state proposals must be submitted with the 15% IDC rate; and
- Research.gov allows our institutional negotiated IDC rate.
We will continue to monitor proposal status and will consider revising this approach if proposals are returned without review on the basis of the IDC rate.
CU Boulder will also hold any awards issued with a 15% IDC rate until a court decision is made.
NIH and Foreign Subawards
On Thursday, May 1, NIH issued NOT-OD-25-104 Updated NIH Policy on Foreign Subawards, announcing that NIH will implement a new award structure by September 30, 2025, such that foreign subawards cannot be nested under a parent grant and will be directly funded by NIH.
- As NIH implements this new award structure, they will not issue new, renewal or non-competing continuation awards that include a foreign subaward.
- The policy and related NIH Extramural News item provide options for PIs.
- We have asked for clarity on a few statements in the policy and news item, including any restriction if a project includes a “foreign component.”
- There is no restriction on submitting proposals with a foreign subaward; however, given that new and renewal awards will not be issued with a foreign subaward, PIs may want to consider whether to include a foreign subaward at this time and timing of their submission.
- PIs with non-competing continuation (incremental) funding expected before the end of 2025 and a foreign subaward have been contacted by OCG.
Please contact your OCG Proposal Analyst about proposal submission questions and your Grant Officer for questions about awards.
Regards,
Alexa Van Dalsem, MA, CRA
Senior Director, Office of Contracts and Grants
Research & Innovation Office
University of Colorado Boulder