Implementation of standard 15% indirect cost rate

NSF is updating its policy regarding the reimbursement of indirect costs in federally funded financial assistance.

Read the policy.

Important information regarding OMB's Supplementary Information for Federal Agency Implementation of 2 CFR 200 (August 15, 2024)

- De minimis rates for new awards: Unless otherwise noted in a program solicitation, recipients may elect to use the new 15% de minimis indirect cost rate for any award executed on or after October 1, 2024.

- De minimis rates for existing awards: Unless otherwise noted by the program solicitation/award letter, awardees may apply the 15% de minimis rate to existing awards, provided that there are sufficient funds to do so and still adequately meet stated project objectives. The 15% de minimis rate may only be charged to costs incurred after October 1, 2024; recipients may not retroactively apply the de minimis rate to costs incurred prior to this date.

SBIR/STTR Phase II Administrative/Financial Reviews

This webpage provides information for prospective Phase II awardees of the U.S. National Science Foundation Small Business Innovation Research (NSF SBIR) and Small Business Technology Transfer (NSF STTR) programs.

When an NSF SBIR/STTR program official is considering recommending your Phase II proposal for funding, NSF will ask you to provide documentation so the agency can evaluate your organization's ability to effectively and efficiently manage a federal award.

This page outlines the information your organization will need to provide to NSF.

How to submit your documentation

If your organization has been directed to this webpage by an SBIR/STTR program official, the documentation they requested must be sent in electronic format (e.g., PDF) within 10 calendar days of the date of the request to bfacapsbir@nsf.gov.

When submitting your materials, please label your files with the document number and name. For example, your documentation for organizational establishment and structure should include "3. Documentation of organizational establishment and structure" as header text or as the document's title. The file name should also reflect the document number and name, e.g., "3_Organizational_establishment_structure.pdf."

NSF uses the services of certified public accountant (CPA) firms to review the documents you submit. If an NSF staff member or contractor contacts you for clarification or additional documentation, you should respond as soon as possible to expedite the review process. Please direct questions on completing the required documentation to bfacapsbir@nsf.gov or (703) 292-8244.

1. Awardee Organization and Management Summary, NSF Form 357

Complete part 1 only.


2. Small Business Declaration, NSF Form 359

If you are a for-profit organization or small business, provide a copy of the Small Business Declaration form.

If you are a nonprofit organization, provide a copy of the current Internal Revenue Service tax exemption letter, which certifies the organization's nonprofit status.


3. Documentation of organizational establishment and structure

Provide an official or published statement of the purpose of your organization and of the power that has been granted to it to enter into contractual relationships and/or accept awards (e.g., articles of incorporation, bylaws). This documentation should include a brief description of your organization's objectives.


4. Organizational chart/segregation of duties

Provide a copy of your organizational chart reflecting the structure of your organization.

Your organization's structure should allow for adequate segregation of duties. For example, no single employee or person should have complete control of accounting transactions and oversight of the daily functions of the NSF project or be in a position that generates a conflict of interest.


5. Listing of current or recent federal awards

Provide a listing of all federal awards (including grants, contracts and cooperative agreements) received by your organization over the past two years. For each award, please provide the name of the agency, award number, award amount and title of the project.


6. Financial Management Systems Questionnaire, NSF Form 358

Complete the questionnaire and sign the form.


7. Single audits

An organization that expends $750,000 or more in federal awards during its fiscal year must have had a single audit conducted in accordance with 2 CFR 200, Subpart F "Audit Requirements".

Provide your organization's single audit reports if you have met the $750,000 expenditure requirement for both or any of your two most recently ended fiscal years.


8. Financial statements

NSF performs a financial capability review on every prospective Phase II awardee to ensure that the organization is financially stable, has sufficient resources to complete its research program and does not expose the government to the possibility of waste, fraud or abuse of funds. NSF will decline funding when an organization is unable to demonstrate that it has sufficient financial resources as of the evaluation date or if NSF believes there is a risk of inappropriate use of federal funds. NSF reviews an organization's:

  • Solvency (i.e., the level of capital invested by shareholders).
  • Debt obligations.
  • Liquidity (i.e., cash resources on hand to satisfy financial obligations).
  • Historical profit and loss.
  • Cash flows.
  • Operating trends.
  • Financial commitments.

Additional information may be requested to support an organization's financial capability, such as operating budgets, cash flow forecasts, lines of credit, details of liabilities, committed investments, other grant or revenue sources, updated interim financial statements, bank statements, etc.

The following documentation should be included to support NSF's review of your organization's financial statements:


9. Project cost ledger

Provide a project cost ledger showing actual expenses from your SBIR/STTR Phase I project.

If a project cost ledger from your Phase I project is not available, then your organization should submit a copy of your general ledger showing your accounting for normal organizational expenditures during the latest accounting period. (The project expense ledger can be queried from the general ledger for a specific grant project's fund/account to show revenues and incurred expenses under the grant project.) The documentation you submit should show how your organization tracks grant-project expenditures by line item, reconciles current expenditures to the amount budgeted, and keeps grant-project expenditures separate from organizational expenditures.

See item 9 in the New Awardee Checklist in the Prospective New Awardee Guide for details.


10. Chart of accounts

Provide an up-to-date chart of accounts of revenue and expense codes/accounts used for recording revenues and expenses under federal grant projects.

If your proposal contains participant support, please also identify in the chart of accounts which expense codes/accounts are used to segregate participant support costs.

See item 10 in the New Awardee Checklist for details.


11. Compensation - personal services

Provide current written policies and procedures for compensation of personal services or salaries and wages to address the processes for allocating, reporting and certifying effort under federal grant awards.

Please also provide a sample of the effort reports/attendance records your organization intends to use to document the effort charged to the NSF project. Note: Social Security numbers (SSNs) and other personal data should be redacted.

See item 11 in the New Awardee Checklist for details.


12. Allowable costs

Provide the current accounting policies and procedures in place at your organization governing the types of expenditures that can be made under federally sponsored projects. These should include how your organization will evaluate costs to ensure that they are necessary, reasonable, allocable and allowable. Policies should also include identification and treatment of strictly unallowable costs such as alcohol, entertainment, etc., as prescribed by 2 CFR 200 Subpart E "Cost Principles" and 2 CFR 200 420–475 – "General Provisions for Selected Items of Cost."

See item 12 in the New Awardee Checklist for details.


13. Participant support

If your proposal contains participant support, provide your organization's current written policies and procedures governing participant support (who is considered a participant, what types of costs can be charged, NSF restrictions on re-budgeting out of participant support, non-recouping of indirect costs, and segregation of incurred participant support costs in the accounting system). Please see the note under "10. Chart of accounts" for additional information.

See item 13 in the New Awardee Checklist for details.


14. Subaward monitoring policies and subaward agreement

If your proposal contains a subaward, provide the current subaward monitoring policies and procedures in place at your organization, and a copy of the proposed subaward agreement, if already executed. If the proposed subaward agreement is not yet executed, provide a sample copy of any executed subaward agreement.

See item 14 in the New Awardee Checklist for details.


15. A note on cost sharing

Mandatory and voluntary committed cost sharing is prohibited on SBIR/STTR Phase II awards. Please contact your NSF program officer if you have any questions or concerns.


16. Support of indirect costs

No documentation is required to support budgeted indirect costs when the sum of the proposed indirect costs and fringe benefit costs are at or below 50% of the total proposed salaries and wages (S&W); this amount is known as the NSF "Safe Rate."

Otherwise, provide a copy of your organization's current negotiated indirect cost rate agreement. If you do not have a negotiated indirect cost rate and are requesting indirect costs in excess of the "de minimis" rate of 15% of modified total direct costs, you must submit a full indirect cost rate proposal for review (see item 18).


17. Current payroll registers or pay stubs

Required for all project personnel with a proposed annualized salary in excess of $50,000 (Note: SSNs and other personal data should be redacted).


18. Indirect cost rate proposal

If you do not have a negotiated indirect cost rate and are requesting indirect costs in excess of the "de minimis" rate of 15% of modified total direct costs (for awards executed on or after October 1, 2024), submit a full indirect cost rate proposal for review. It must be reconciled to the most recently completed financial statements.


19. Financial management or accounting system audits

Copies of any financial management or accounting system audits conducted by the Defense Contract Audit Agency or any other federal agency during the past five years.


20. Information to support budget review

Small businesses are cautioned that it is their responsibility to provide adequate explanation and documentation to support budgeted costs. Funding recommendations will not be revised based on new documentation or explanations provided after the completion of budget reviews.

For NSF to review your Phase II proposal budget, provide the following information: