NSF Indirect Cost Policy FAQs
Q1: Will OSP submit proposals to funding opportunities with hard or immediate deadlines that include NSF’s new 15% indirect cost rate cap?
A1: OSP will not submit a proposal responding to a funding opportunity issued May 5th or later, or any funding opportunity that incorporates the NSF IDC cap policy. This is true even if the budget is built using UW’s current negotiated rates and even if it has a more immediate deadline.
Q2: Our PI is responding to an NSF opportunity that does not contain the new NSF IDC cap. Should we proceed?
A2: It is up to the PI and collaborators whether they want to invest the time knowing the following. There is litigation pending. If a court decision is made prior to submission, that decision may influence whether we submit:
- If we do not submit based on that court decision outcome (i.e. decision not in our favor and need to appeal), it would mean a lot of work on the part of the PI and collaborators for naught. A decision in favor of Institutes of Higher Education (IHEs) would mean we’d most likely proceed with submission, depending on the decision.
- If no court decision prior to the due date, we can proceed with a submission at the regular {full negotiated rate}. This does not mean NSF will accept the proposal at this rate, or if considered, it will make an award at this rate. If an award were made at the 15% rate despite our use of {our full negotiated rates}, it will be held in OSP similar to other NSF awards in the same position.
This approach is based on the fact the request for application (RFA) was posted prior to the new NSF IDC cap policy and the RFA was not updated to include reference to the cap. If it is updated to include the cap requirement, OSP will not submit.
Q3: If we prepare a proposal and send it to OSP is OSP going to provide a review or are reviews on hold as well?
A3: If OSP were to receive proposals to NSF, we will not be reviewing unless we know there is a submission path in alignment with University policy.
Q4: Can a proposed subrecipient use the 15% cap even if UW does not?
A4: Note that we are not submitting to an NSF funding opportunity issued May 5th or later, or any funding opportunity that incorporates the NSF IDC cap policy. Therefore, this is only applicable for proposals that fall under the scenario in the response to Q2. A proposed subrecipient can use the capped rate, if the subrecipient entity submits their approved budget that way, for use in UW’s proposal. Note that if there is a court decision in IHE’s favor, UW will not be rebudgeting the overall project budget to account for use of subrecipient’s negotiated rate, if awarded.