Indirect Cost Guidance for Recipients of EPA Assistance Agreements
Revision Notification/Effective Date: November 12, 2020
Original Notification Date: August 21, 2018
Purpose of Revision: This Recipient/Applicant Information Notice (RAIN) informs recipients and applicants of revisions from the Office of Management and Budget which revised 2 CFR Part 200 effective November 12, 2020, in part to streamline Indirect Cost (IDC) regulations to provide further flexibility for the use of the 10% de minimis indirect cost rate authorized in 2 CFR 200.414(f). EPA’s IDC Policy and Guidance has been updated to reflect these changes.
Purpose: This Recipient/Applicant Information Notice (RAIN) informs recipients and applicants of a new policy that aligns IDCs under EPA assistance agreements (grants and cooperative agreements) with 2 CFR Part 200, while providing consistency and flexibility for EPA assistance agreement recipients.
Background: The implementation of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards at 2 CFR Part 200 revised IDC flexibilities and requirements. This policy seeks to align EPA and recipient practices with 2 CFR Part 200, while balancing the need for flexibility.
Policy Summary: Prior to drawing down EPA funds for IDCs, and/or using unrecovered IDCs as cost- share, recipients must have an approved rate and an EPA-approved budget that includes IDCs. The IDC Policy defines different approved IDC rate types, which now includes use of the 10% de minimis rate as long as an applicant does not have a current negotiated rate under 10% or is not exempt from using the de minimus rate. In addition, the policy includes regulatory exception opportunities, that require EPA approval, on a case-by-case basis that can increase recipient options, such as:
- Continued use of fixed rates with carry-forward for up to four years past expiration;
- (Institutions of Higher Education Only) Use of current negotiated rate, rather than using the same rate for the life of the grant; and
- General exceptions if a recipient has been out of compliance with the IDC requirements set forth in 2 CFR Part 200.
- Indirect Cost Policy for Recipients of EPA Assistance Agreements (pdf)
Indirect Cost Guidance for Recipients of EPA Assistance Agreements (pdf)
This Indirect Cost Guidance for EPA Assistance Agreements (IDC Guidance) is intended to assists applicants and recipients with regulatory compliance.
- Statutory Restrictions on Indirect Costs in EPA Financial Assistance Programs (pdf)
- RAIN-2018-G02-R (pdf)