F&A 10% de minimis
The Guidance allows MIT to provide a de minimis F&A rate of 10% modified total direct costs (MTDC) to subawardees who do not have a federally negotiated rate. Subaward budgets to MIT should clearly state whether the de minimis indirect costs are being utilized. Check with RAS’s Research Subawards Team to determine whether a proposed subrecipient has a negotiated rate.
Applicable Uniform Guidance section: 200.414
NIH Deviation from 10% de minimis: For subawards to foreign organizations, NIH limits the reimbursable F&A costs to 8% of the modified total direct costs (MTDC) less only capital equipment.
Fixed Price Subwards
MIT may issue fixed price subs under limited circumstances, usually to higher risk organizations. Under the new Guidance, such subawards require specific sponsor approval, and may not exceed $150,000.
Subaward Performance Monitoring
The new subaward monitoring requirements stress the need for MIT to document how it monitors subawardees. PIs are reminded that invoices should only be paid if the subawardee is making adequate progress towards achieving performance goals. Expenses should be commensurate with progress to date. Performance issues must be addressed as they arise, for example payments should be withheld and problems escalated, as needed.
High risk subawards must be carefully evaluated and monitored through the life of the award, and additional oversight measures may be required depending on the experience level of the institution.
Applicable Uniform Guidance section: 200.330 and 200.331