#  NIH Update: $25K Subaward Threshold and Required Adjustments  

 





May 12, 2026

 

 

NIH has issued Notice [**NOT-OD-26-072**](https://grants.nih.gov/grants/guide/notice-files/NOT-OD-26-072.html), which rescinds prior notices and advises that the $25,000 Modified Total Direct Costs (MTDC) threshold for outgoing subawards remains in effect. The previously communicated $50,000 MTDC threshold no longer applies to NIH awards.

## Pre-award: 

- All NIH proposals should budget subawards using the $25,000 MTDC threshold effective immediately.
- **Rebudget Requests:** For new and competing NIH awards issued on or after 7/1/25, your pre-award office will review any subawards set up in the Grants Management Application Suite (GMAS) using the $50,000 threshold and will contact you to address any necessary rebudgeting resulting from the reduction of the MTDC threshold from $50,000 to $25,000.

## Post-award: 

- For new and competing awards issued on or after 7/1/25 that were set up in GMAS using the $50,000 threshold, we will be reviewing subaward expenses that exceeded $25,000. Your OSP Research Finance contact will reach out to impacted departments to complete required journal entries to move applicable costs from 8190 to 8191.
- Moving forward, all subaward charges exceeding $25,000 on NIH awards should be directed to 8191.

Additionally, NOT-OD-26-072 removes the flexibility for subawardees without a negotiated rate to apply the increased 15% de minimis indirect cost rate, limiting them to a 10% indirect cost rate.

## Key Takeaways: 

- Update proposal budgets immediately to reflect the $25,000 MTDC outgoing subaward threshold for NIH awards only.
- Use the $25,000 threshold for all NIH subawards.
- Review active NIH awards with start dates on or after 7/1/25 for potential over collection of indirect costs and work with your Research Finance contact on any adjustments.
- Continue using the $50,000 threshold for subawards for all other sponsors on new and competing awards issued on or after 7/1/25.

## Questions? 

- For budgeting, proposal preparation, and rebudgeting questions, please reach out to your pre-award office contact.
- For post-award questions, please contact your OSP Research Finance contact.



 

 

 



 

 See also:- [ NIH ](/blog-tags/nih)