The Council on Governmental Relations (COGR) submitted a formal letter to the National Institute of Food and Agriculture (NIFA) expressing concerns about the recently issued implementation guidance relating to Section 1462(c), Treatment of Subgrants, under the National Agriculture Research, Extension, and Teaching Policy Act of 1977 as amended by the 2018 Farm Bill. While COGR affirms its commitment to compliance and acknowledges NIFA’s ongoing support for research institutions, it argues that the new guidance creates confusion and significantly increases administrative burden, particularly regarding the calculation and application of indirect cost rates for prime recipients and subrecipients. COGR contends that the intent of the statutory change was to formalize existing practices, not to complicate or alter them in a manner that would hinder partnerships or create inefficiencies.
COGR requests that NIFA suspend the new guidance and temporarily revert to its previous approach until concerns are addressed collaboratively. The letter specifically highlights issues such as ambiguity in interpreting Congressional intent, increased administrative challenges affecting proposal development and collaboration, and the potential deterrent effect on research partnerships. It also suggests alternatives for streamlining compliance, such as aggregate calculation over the award’s lifespan or adopting collaborative award models similar to those of the National Science Foundation. Additionally, COGR seeks confirmation of the continued acceptability of the Indirect Cost (IDC) Match under the Specialty Crop Research Initiative (SCRI) and other NIFA programs as previously agreed. The organization offers to work jointly with NIFA to refine the guidance, promoting clarity and efficiency for all stakeholders involved in agricultural research funding.
