Association Executive Directors Community

Comments on OMB Revised Federal Guidance on Grants and Agreements – 12/1/23

  • 1.  Comments on OMB Revised Federal Guidance on Grants and Agreements – 12/1/23

    National Council Staff
    Posted 12-01-2023 13:54

    Dear Association Executives - The Office of Management and Budget (OMB) has proposed to revise parts of the Guidance for Grants and Agreements located in Title 2 of the Code of Federal Regulations. Some of the specific changes being contemplated are:

    • Raising the guaranteed de minimis rate for indirect costs from 10% to 15% of modified total direct costs. As OMB states, "This change would allow for a more reasonable and realistic recovery of indirect costs, particularly for new or inexperienced organizations that may not have the capacity to undergo a formal rate negotiation, but still deserve to be fully compensated for their overhead costs."
    • Clarifying that federal agencies may not compel recipients and subrecipients to use an indirect rate lower than the proposed 15% rate, unless required by statute. Organizations can choose not to utilize the 15% minimum, but they cannot be forced to.
    • Requiring that pass-through entities, typically state and local governments, must accept all federally negotiated indirect cost rates for subrecipients. This would mean that nonprofits with negotiated rates with one agency would have to be paid that same rate by other agencies.
    • Revising Notices of Funding Opportunities (NOFOs), so they include basic information at the top of a grant announcement, so that applicants can more easily make decisions about whether to apply.

    OMB is currently seeking comments on the proposed changes. We encourage you to provide comments on the changes that will impact how your organization receives and manages federal grants and agreements. 

    • If you would like to submit comments on the OMB proposal, they must be submitted electronically at before Monday, Dec. 4.

    To help you, we have created a comment template for the OMB proposal that addresses the areas we think are most relevant to our members. Simply fill in the placeholders with basic information about your organization before submitting your comments.

    Please let me or Peter Delia, Manager, Federal Policy ( know if you have questions or if any additional information would be helpful. Please feel free to share this with your members. We will also be sharing this with National Council members.  

    Reyna Taylor
    Senior Vice President, Public Policy and Advocacy
    National Council for Mental Wellbeing
    Direct – 202-774-1651

    Neal Comstock
    Director of Membership
    National Council
    202 748-8793