The document summarizes concerns and challenges faced by research universities regarding changes introduced by the 2018 Farm Bill (Agriculture Improvement Act of 2018) and corresponding agency guidance, particularly in the administration of federally funded agricultural research, education, and extension grants. Key issues include the introduction of a matching requirement for certain programs, reinterpretation of the capped indirect cost (F&A) rate—which now applies collectively to primes and all subrecipients rather than only the prime recipient—and new limitations on both reimbursed and cost-shared F&A, effectively capping total indirect cost recovery at 30% of Total Federal Funds Awarded (TFFA). These changes have increased administrative and financial burdens for grant recipients by complicating budget structures and compliance, especially as cost-sharing arrangements are now also restricted under the F&A cap.
Discussions with the National Institute of Food and Agriculture (NIFA) leadership revealed that these changes stem from the absence of waiver authority—previously available under the 2014 Farm Bill—but not included in the 2018 legislation, partly due to legislative oversight around the time of a federal government shutdown. Further, concerns were raised that previously, NIFA’s implementation may not have fully complied with congressional intent regarding F&A limits. To address the resulting challenges, various remedies are under consideration, including potential legislative or regulatory corrections, new mechanisms for collaborative proposals, and harmonization of time and effort reporting requirements. The USDA has indicated heightened attention to resolving these issues, with senior leadership and advocacy organizations actively engaged in seeking solutions and monitoring compliance. Continued follow-up by university committees and stakeholder groups is planned to address the administrative and financial impacts introduced by the 2018 Farm Bill.
