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How do I request a regulatory exception to use an expired ‘fixed rate with carry-forward’ IDC agreement?

For rates that have expired, EPA may approve a regulatory exception to allow a recipient with a fixed rate with carry-forward to continue to use the fixed rate for up to four additional fiscal years after the rate's expiration date. Please note you must submit a regulatory exception to continue to use an expiring/expired fixed rate with carry-forward request to EPA for approval. 

Instructions follow below on how to continue to use an Expiring/Expired fixed rate with Carry-Forward:

The applicant/recipient should email the exception request to OMS-OGDWaivers@epa.gov, copy the EN grant program at ENGrantProgram@epa.gov when submitting the exception request, and:

  1. The email subject should be "IDC Regulatory Exception." Include grant numbers for all current grants with the EPA. These numbers are available on the EPA grant award documents, and will start with the Program Code (such as "GA" for a GAP grant) and then eight alphanumeric characters (such as J0110962)
  2. Include the Recipient Organization's Name, as shown in www.SAM.gov
  3. Include the Recipient Organizations Unique Entity Identifier (currently the Dunn and Bradstreet or DUNS) Number
  4. Include the recipient Organization's Contact Information (email address, mailing address, and phone number)
  5. Include a statement that the applicant/recipient is requesting an exception to the requirement at 2 CFR 200.414© that it charge indirect costs based on an approved rate
  6. Include a justification for the exception (description of why the exception is needed, any extenuating circumstances that may prevent compliance with the requirement to obtain an approved fixed rate with carry forward prior to expiration)
  7. Include a copy of the most recent IDC rate agreement; and
  8. Include any additional information that may help EPA to make a determination.

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Last updated on February 3, 2025
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