BIOMEDICAL 

RESEARCH

NIH Should Assess the 

Impact of Growth in 

Indirect Costs on Its 

Mission

Report to the Ranking Member, 

Committee on the Budget, U.S. Senate

September 2013

GAO-13-760

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-760, a report to the 

Ranking Member, Committee on the Budget, 

U.S. Senate

September 2013

BIOMEDICAL RESEARCH

NIH Should Assess the Impact of Growth in Indirect 

Costs on Its Mission

Why GAO Did This Study

NIH reimburses universities for both 

the direct and indirect costs of 

conducting research. Indirect costs 

cover general facility and 

administrative expenses, and are paid 

as a percentage, or rate, of certain 

direct costs of awarded grants. GAO 

was asked to look at the indirect costs 

of NIH-funded research. This report 

(1) identifies changes in 

reimbursements by NIH to universities 

for indirect costs of NIH-funded 

research; and (2) examines key factors 

affecting NIH reimbursement to 

universities for indirect costs and what 

assessment NIH has done to address 

any impact of these costs on NIH’s 

research mission. GAO analyzed NIH 

data and interviewed officials at NIH, 

six universities, and other 

stakeholders. Universities were 

selected based on the number of 

grants and amount of funding received 

from NIH and their negotiated indirect 

cost rates.

What GAO Recommends

GAO recommends that NIH assess the 

impact of growth in indirect costs on its 

mission, including, as necessary, 

planning for how to deal with potential 

future increases in indirect costs that 

could limit the amount of funding 

available for total research. HHS 

agreed with GAO’s recommendation 

but disagreed with a number of GAO’s 

conclusions, stating that risk to NIH’s 

mission is low because indirect costs 

remain a stable percentage of NIH’s 

budget. Due to indications that indirect 

costs for universities may increase in 

the future, GAO believes that 

continually assessing and planning for 

the impact of growth over the long term 

is important. 

What GAO Found

From fiscal year 2002 to fiscal year 2012, indirect cost reimbursements from the 

National Institutes of Health (NIH) to universities increased slightly faster than 

those for direct costs, but increased notably faster during some periods. 

Specifically, from fiscal years 2002 to 2012, indirect costs increased 28.1 percent 

while direct costs increased 27.0 percent. However, for the fiscal years 2003 to 

2012, indirect costs increased notably faster than direct costs, at 16.9 percent 

and 11.7 percent, respectively. In more recent years, annual changes were 

generally small but consistent. This increase occurred during a time when growth 

in NIH’s budget for extramural research slowed to 5 percent from fiscal years 

2008 to 2012, compared to about 21 percent from fiscal years 2002 to 2007. In

fiscal year 2012, about 10 percent of the universities (50 out of about 500) 

receiving NIH extramural research funding received almost 70 percent of all 

indirect cost reimbursement provided to universities. Higher indirect cost rates 

tended to be associated with universities located in high-cost-of-living areas and 

privately owned universities.

Stakeholders—university officials, Department of Health and Human Services 

(HHS) officials, and others—whom GAO interviewed identified several key 

factors that may lead to increases in reimbursements for indirect costs provided 

to universities. Some stakeholders reported that reimbursements for one part of 

indirect costs—the facilities component—help to support research innovation by 

providing funding for the development and maintenance of state-of-the-art 

research facilities. However, officials in HHS’s Division of Cost Allocation, which 

is responsible for determining indirect cost rates, stated that the uncapped 

facilities component of the indirect cost rate provides universities with few, if any, 

incentives for controlling these costs. For example, these officials noted that 

there is no limit on reimbursement for interest costs under the facilities 

component. This may encourage universities to borrow money to build new 

facilities, which could lead to building more new space than is necessary for 

research. Some stakeholders also noted that a 26 percent cap on the 

reimbursement rate for administrative costs—a second component of indirect 

costs—helps to control reimbursements for those costs; however, they reported it 

does not account for the recent increases in costs, such as those for regulatory 

reporting requirements and changing research needs that require advanced 

medical and information technologies that are considered administrative.

The combination of these trends and factors results in indirect costs growing at a 

faster rate than direct costs. Indirect costs are one-fifth of NIH’s total budget—or 

$6.2 billion in fiscal year 2012—but NIH officials reported that they have not 

taken steps to assess the significance of future indirect cost growth for 

universities, or planned for options that might address these trends or factors—in 

part because they view increases in indirect costs as having been modest. 

However, factors suggest that indirect costs could increase more quickly in the 

future. Over the long term, they could lead to a reduction in the number of 

research grants that could be funded, thus potentially affecting scientific 

discoveries and knowledge. View GAO-13-760. For more information, 

contact Linda T. Kohn at (202) 512-7114 or 

kohnl@gao.gov.
Page i GAO-13-760 NIH Indirect Cost Funding

Letter 1 

Background 5

From 2002 to 2012, NIH Indirect Cost Reimbursements to 

Universities Increased Faster than for Direct Costs, with Most 

Going to a Small Number of Universities 11

Stakeholders Identified Factors Related to Facilities and 

Administrative Costs That May Increase Reimbursements for 

Indirect Costs, but NIH Has Not Assessed Their Potential Impact 16

Conclusions 19

Recommendation 20

Agency Comments and Our Evaluation 20

Appendix I Indirect Costs and Rates for the Top 50 National Institutes 

of Health—Funded Universities, Fiscal Year 2012 23

Appendix II Comments from the Department of Health and Human 

Services 25

Appendix III GAO Contact and Staff Acknowledgments 31

Table

Table 1: Characteristics of the 10 Universities with the Highest 

Indirect Cost Rates among the 50 Universities Receiving 

the Highest Amounts of Indirect Cost Reimbursement, 

Fiscal Year 2012 15

Figures

Figure 1: Total Direct Costs and Modified Total Direct Costs 9

Figure 2: Percent Change from the Prior Year in Reimbursement 

for Direct and Indirect Costs, Fiscal Year 2003 to Fiscal 

Year 2012 12

Contents 
Page ii GAO-13-760 NIH Indirect Cost Funding

Abbreviations

DCA Division of Cost Allocation

DOD Department of Defense

HHS Department of Health and Human Services

IC institutes and centers

IT information technology

MTDC modified total direct costs

NIH National Institutes of Health

OMB Office of Management and Budget

ONR Office of Naval Research

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Page 1 GAO-13-760 NIH Indirect Cost Funding

441 G St. N.W.

Washington, DC 20548

September 24, 2013

The Honorable Jeff Sessions

Ranking Member

Committee on the Budget

United States Senate

Dear Senator Sessions:

The federal government has recognized that research conducted at 

universities contributes to American competitiveness and leadership in 

science and has committed to sponsoring a share of the research costs.1

To be reimbursed for direct and indirect costs, universities must properly 

identify and claim reimbursement for these costs in accordance with 

applicable federal guidance. Office of Management and Budget (OMB) 

Circular No. A-21 establishes the principles for determining the types of 

direct and indirect costs that are allowed to be claimed and the methods 

for allocating such costs to federally funded research at educational 

The Department of Health and Human Services’ (HHS) National Institutes 

of Health (NIH) is the nation’s leader in conducting and sponsoring 

biomedical research. A large portion of this research is extramural 

research conducted at universities nationwide, which is an essential part 

of how NIH fulfills its mission—to understand the nature and behavior of 

living systems and to improve health. In fiscal year 2012, $25.2 billion—or 

over 80 percent of NIH’s budget of $30.8 billion—was used to support 

extramural research. NIH reimburses universities for both the direct and 

the indirect costs of conducting biomedical research. Direct costs can be 

specifically attributed to research projects sponsored by NIH grants, 

including costs for labor and materials used solely to carry out sponsored 

research. Indirect costs are not directly attributable to a specific project 

and include various facility and administrative expenses incurred by the 

universities for the shared support of such research. Indirect costs 

represented approximately $6.2 billion in fiscal year 2012, or 20 percent 

of NIH’s budget.

 

1

For the purposes of this report, the term “universities” refers to domestic higher education 

institutions.

 
 

Page 2 GAO-13-760 NIH Indirect Cost Funding

institutions.2 Because indirect costs cannot be specifically attributed to a 

particular research grant, they are charged via an indirect cost rate that is 

applied to certain direct costs for each awarded grant.3 Each university 

negotiates an indirect cost rate, based on information such as the amount 

of physical space used for conducting research. Most universities 

negotiate their indirect cost rate with HHS’s Division of Cost Allocation 

(DCA).4 Generally, the rate stays in effect for 2 to 4 years, at which time a 

new proposal is developed and the rate is renegotiated. Once a 

university’s indirect cost rate has been established, a federal agency will 

generally apply that rate to all grants issued to that university.5

All federal agencies, including NIH, are responsible for implementing 

internal controls to, among other things, provide reasonable assurance 

that the agency is achieving its goals by operating in an effective and 

efficient manner.6 A key element of internal control is risk assessment, 

which is the identification and analysis of relevant risks associated with 

achieving the agency’s objectives. As we previously reported, NIH has a 

program to periodically identify, analyze, and manage significant risks to 

its objectives, strategy and mission.7

 

2

Office of Management and Budget, Cost Principles for Educational Institutions, OMB 

Circular No. A-21 ((incorporated in 2 C.F.R. 220) (2012)).

Since NIH achieves its mission 

largely through extramural research, the indirect and the direct costs of 

3

The indirect cost rate is applied to certain direct costs—referred to as “modified total 

direct costs” (MTDC). For MTDC, certain direct costs or portions of direct costs are 

excluded from total direct costs, such as equipment costs. For example, for a grant award 

with total direct costs of $110,000, a MTDC of $100,000, and an indirect cost rate of 

50 percent, NIH would reimburse the university $50,000 for the indirect costs of research 

for a total grant award of $160,000.

4

OMB Circular No. A-21 assigns responsibility to negotiate rates to either HHS or the 

Department of Defense (DOD). (OMB Circular A-21, G, 11, a, (1).) DCA handles this 

responsibility within HHS, and the Office of Naval Research (ONR) does so for DOD. As 

of 2010, DCA is responsible for negotiating rates with more than 1,000 universities, while 

ONR is responsible for 44 universities.

5

While OMB Circular No. A-21 requires agencies to adhere to the negotiated rate while it 

is in effect, an agency may apply a different rate when required by law or regulation. 

(OMB Circular A-21, G,11, b.)

6

See GAO, Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: Nov. 1, 1999).

7

See GAO, National Institutes of Health: Completion of Comprehensive Risk Management 

Program Essential to Effective Oversight, GAO-09-687 (Washington, D.C.: Sept. 11, 

2009).
 

Page 3 GAO-13-760 NIH Indirect Cost Funding

extramural research have the potential to affect NIH’s ability to achieve its 

objectives and mission.

We have previously reported that indirect costs can change over time and 

that indirect cost rates at universities varied widely.8 Furthermore, we 

have noted that there has been debate over what portion of indirect costs 

is the responsibility of the government and what portion is the 

responsibility of the university.9

1. identify changes in the reimbursements paid by NIH to universities to 

support indirect costs of NIH-funded research and examine the 

characteristics of the top recipients of this funding, such as the type of 

institution and the geographic location; and

Given our past work, you requested that 

we provide information on the indirect costs for NIH-funded extramural 

research. In this report, we

2. examine the key factors affecting reimbursement to universities for the 

indirect costs of NIH-funded research and what assessment NIH has 

done to address any impact of these costs on NIH’s research mission.

To identify changes in the reimbursements paid by NIH to universities to 

support the indirect costs of NIH-funded research and examine the 

characteristics of the top recipients of this funding, we obtained 

information from NIH on the total amounts of direct and indirect costs paid 

to universities for NIH research grants over the past decade (from fiscal 

year 2002 through fiscal year 2012).10

 

8

See GAO, National Institutes of Health Extramural Research Grants: Oversight of Cost 

Reimbursements to Universities, 

We analyzed the data provided by 

NIH and identified the top universities—those receiving the most NIH 

indirect cost funding—as well as the various characteristics associated 

with these universities. We also obtained and reviewed data from HHS’s 

DCA on the indirect cost rates for almost 300 universities that received 

NIH research grant funding from fiscal year 2002 through fiscal year 

GAO-07-294R (Washington, D.C.: January 31, 2007); 

and University Research: Policies for the Reimbursement of Indirect Costs Need to Be 

Updated, GAO-10-937 (Washington, D.C.: Sept. 8, 2010).

9

See GAO-10-937. 

10Our analysis focused on the relative differences between changes for indirect cost 

reimbursements and direct cost reimbursements. Therefore, we do not adjust the changes 

in reimbursements for inflation.
 

Page 4 GAO-13-760 NIH Indirect Cost Funding

2012.11

To assess the reliability of NIH’s grant funding data (including the data on 

direct and indirect cost funding), we reviewed our prior work using these 

data and obtained information from agency officials knowledgeable about 

the reliability of the data. We performed data quality checks to assess the 

reliability of the data received from both NIH and DCA. These data quality 

checks involved an assessment to identify missing or incorrect entries or 

outliers. Based on the information we obtained and analyses we 

conducted, we determined that the data we used were sufficiently reliable 

for the purposes of this report.

We reviewed the indirect cost rates among the top universities 

and identified various characteristics—such as the local cost of living 

index, the type of institution, and the geographic location—associated 

with those universities.

In addition, we interviewed stakeholders—including officials with (1) NIH, 

(2) DCA, (3) the Council on Governmental Relations, an association of 

academic research institutions, (4) the Association of American 

Universities, and (5) 6 selected universities—about the amount of funding 

and key characteristics of the 50 universities receiving the highest 

reimbursements for indirect costs. We selected the 6 universities from 

among the top 50 recipients of NIH indirect cost funding to include 

universities that varied in terms of their (1) amount of indirect cost funding 

received; (2) current negotiated indirect cost rate; (3) number of grants 

received; (4) local cost of living; and (5) type of university (public versus 

privately funded).12 We focused on the top 50 universities because they 

are responsible for about two thirds of NIH research conducted at 

universities.13

 

11We obtained and reviewed data for approximately 300 “long-form universities,” which 

are those universities that use a “long form” during negotiations with DCA because their 

total federal funding is greater than $10 million per year.

12For indirect cost funding amount, indirect cost rate, and the number of grants, we used 

fiscal year 2012 data. For cost of living, we used the U.S. Census Bureau’s “cost of living 

index” for 2010.

13Our review does not include nonuniversity grantees (such as nonacademic research 

institutions) that received NIH grant funding.
 

Page 5 GAO-13-760 NIH Indirect Cost Funding

To examine the key factors affecting reimbursement to universities for the 

indirect costs of NIH-funded research and what assessment NIH has 

done to address any impact of these costs on NIH’s research mission, we 

reviewed relevant laws, policies, and guidance, and interviewed relevant 

officials. Documents we reviewed included OMB Circular No. A-21—

which establishes principles on how the federal government reimburses 

universities for the costs of federally funded research—and HHS and NIH 

guidance related to the process for reviewing and negotiating indirect cost 

rate and providing reimbursement of direct and indirect costs. We also 

reviewed proposed revisions to current policies for reimbursement of 

indirect costs issued by OMB and literature from stakeholders that include 

potential changes to address reported disadvantages of current policies, 

and alternative approaches to current policies for providing 

reimbursement for indirect costs. In addition, we interviewed officials from 

HHS’s DCA and NIH about how they implement policies on indirect costs, 

how reported key factors could affect NIH’s funding of future research, 

and what assessment NIH has done to address trends in indirect costs. 

We also conducted interviews with private grant-making foundations that 

support biomedical research to determine their policies on reimbursement 

of indirect costs.

We conducted this performance audit from February 2013 to September

2013, in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

NIH conducts and sponsors biomedical research through its institutes and 

centers (IC), each of which is charged with a specific mission. ICs’ 

missions generally focus on a given disease; a particular organ; or a 

stage in development, such as childhood or old age. ICs accomplish their 

missions chiefly through intramural and extramural research. Intramural 

research entails government scientists working in the ICs’ own 

laboratories and clinics, whereas extramural research is conducted at 

outside research institutions, primarily universities, by scientists who have 

been awarded extramural research grants from an IC through NIH’s 

Background 
 

Page 6 GAO-13-760 NIH Indirect Cost Funding

competitive process.14 More than 80 percent of NIH’s total budget of over 

$30 billion in fiscal year 2012 was used to support extramural research. 

Of this $25.2 billion in extramural research grant funding, NIH provided 

about $16.1 billion to universities.

Extramural research grants reimburse universities for the direct costs of 

each research project covered by the grants and a portion of the indirect 

costs of maintaining their facilities for research use and covering the 

administrative expenses of the university. Direct costs can be specifically 

identified with or directly assigned to individual research projects and are 

relatively easy to define and measure.15 They include, for example, the 

researcher’s salary, subawards,16 equipment, and travel.17 Indirect costs 

represent a university’s general support expenses and cannot be 

specifically identified with individual research projects or institutional 

activities. They include, for example, building utilities, administrative staff 

salaries, and library operations. OMB Circular No. A-21 establishes the 

principles for determining the types of direct and indirect costs that are 

allowed to be claimed and the methods for allocating such costs to 

federally funded research at educational institutions, including the 

establishment and use of indirect cost rates.18

 

14For more information on NIH funding provided to universities, see GAO-07-249R. 

15See OMB Circular No. A-21, D,1.

16A subaward is an award provided by a recipient of a federal award to another 

researcher, for the performance of substantive work under the federal award.

17Certain direct costs or portions of direct costs are excluded when estimating indirect cost 

rates. Examples of these exclusions are equipment and portions of subawards in excess 

of $25,000.

18OMB Circular No. A-21 requires all costs for reimbursement to be allowable, allocable, 

and reasonable, and provides that the federal government bear its fair share of total costs, 

determined in accordance with generally accepted accounting principles, except where 

restricted or prohibited by law. A cost is allowable if it is reasonable, is allocable to the 

agreement, is treated consistently with generally accepted accounting principles 

appropriate to the circumstances, and conforms to principles in OMB Circular No. A-21 

and the sponsoring agreement. A cost may be considered reasonable if the nature of the 

goods or services acquired or applied, and the amount involved, reflect the action that a 

prudent person would have taken under the circumstances prevailing at the time the 

decision to incur the cost was made. A cost is allocable to a particular cost objective (i.e., 

a specific function, project, sponsored agreement, department, or the like) if the goods or 

services involved are chargeable or assignable to such cost objective in accordance with 

relative benefits received or other equitable relationship. (OMB Circular No. A-21, C.)

Components of Direct and 

Indirect Costs
 

Page 7 GAO-13-760 NIH Indirect Cost Funding

Indirect costs are divided into two main components, facilities costs and 

administrative costs. Facilities costs include

• operations and maintenance expenses, such as for utilities;19

• allowances for depreciation and use of buildings and equipment;

• interest on debt associated with building and equipment; and

• library expenses, such as for the use of the library and library 

materials purchased for research use.

Administrative costs include

• general administration expenses, such as the costs associated with 

executive functions like financial management;

• departmental administration expenses, including clerical staff and 

supplies for academic departments;

• sponsored projects’ administration expenses, which are the costs 

associated with the office responsible for administering projects and 

awards funded by external sources; and

• student administration and services expenses, such as the 

administration of the student health clinic.

Because indirect costs cannot be specifically attributed to a particular 

research grant, they are charged via an indirect cost rate that serves as 

the mechanism for determining the proportion of indirect costs that may 

be charged to federally funded research awards. OMB Circular No. A-21 

outlines the process for establishing an indirect cost rate for universities 

performing federally funded research. Each university develops a 

proposed indirect cost rate that is based on university cost data from prior 

years, which is subsequently negotiated with the federal government to 

 

19Certain universities are eligible for a rate increase of 1.3 percent to account for the cost 

of utilities—known as the utility cost adjustment.

Calculation of the Indirect 

Cost Rate
 

Page 8 GAO-13-760 NIH Indirect Cost Funding

arrive at a final indirect cost rate, in compliance with the principles of 

OMB Circular A-21.20

To calculate a university’s indirect cost rate, a percentage of each indirect 

cost component is allocated to the university’s research function on the 

basis of benefits received from that component by the research function. 

For example, a university can measure the square footage of floor space 

used for research and use this measure to allocate the amount of costs it 

claims for operating and using the space as a component in its indirect 

cost rate proposal. Each indirect cost component allocated to research is 

applied to a modified set of direct costs referred to as “modified total 

direct costs” (MTDC) to obtain an individual rate for each component.21

MTDC includes the salaries and wages of those conducting the research, 

fringe benefits (e.g., pensions), materials and supplies, travel, and the 

first $25,000 of each subaward. MTDC excludes costs such as equipment 

costs, capital expenditures, tuition remission,22 equipment or space rental 

costs, and the portion of each subaward in excess of $25,000.23

 

20While OMB Circular No. A-21 requires agencies to adhere to the negotiated rate while it 

is in effect, an agency may apply a different rate when required by law or regulation. 

(OMB Circular A-21, G,11, b.)

(See 

fig. 1.)

21Universities use a standard format, also known as the long form, for submitting their 

indirect cost rate proposals to their cognizant rate-setting agency. However, universities 

whose total direct costs on federal awards do not exceed $10 million in a fiscal year may 

use a simplified method for determining the indirect cost rate applicable to all federal 

awards. Whereas universities above the $10 million threshold must use an MTDC base, 

universities using the simplified method may use either salaries and wages as their base, 

or MTDC. As already noted, this report focuses on those universities that used the 

standard format for proposal submission.

22Tuition remission is compensation provided to graduate research assistants in lieu of 

salary.

23Costs for subawards over $25,000 and equipment are excluded because they can 

involve very large expenditures but usually do not require the university’s facilities and 

administrative support.
 

Page 9 GAO-13-760 NIH Indirect Cost Funding

Figure 1: Total Direct Costs and Modified Total Direct Costs

The indirect cost rate is developed as follows:

• Each portion of the facilities costs (i.e., building use, depreciation, 

operations and maintenance) is divided by MTDC and then added 

together to derive the facilities component of the rate.

• Similarly, each portion of the administrative costs (i.e., general 

administration, sponsored administration) is divided by MTDC and 

then added together to derive the administrative component of the 

rate—which is capped at 26 percent.

• These individual rates—the facilities and administrative—are then 

summed to obtain the university’s indirect cost rate for research.

In 1991, OMB revised Circular No. A-21 to impose a cap of 26 percent on 

the administrative component of the indirect cost rate. This cap was 

established to curb growth in the amount of indirect costs reimbursed to 
 

Page 10 GAO-13-760 NIH Indirect Cost Funding

universities.24

A university submits a proposal to the federal agency responsible for 

negotiating a final rate—typically DCA. DCA reviews the submitted 

proposal and negotiates a final indirect cost rate with each university. 

DCA is responsible for providing technical assistance and guidance to the 

grantee community in developing indirect cost rate proposals, reviewing 

cost accounting practice disclosure statements, and negotiating and 

approving university indirect cost rates.

This limitation only applies to higher education institutions, 

as stated in OMB Circular No. A-21.

In February 2013, OMB issued proposed guidance that includes revisions 

to cost principles of OMB Circular No. A-21.25 The proposed guidance 

reflects input from the federal and nonfederal financial community, 

including the Interagency Council on Financial Assistance Reform.26 The 

proposed guidance would, among other things, allow more items to be 

directly charged rather than included as a component of the indirect cost 

rate.27 As of September 2013, OMB had not issued final guidance.

 

2456 Fed. Reg. 50224 (Oct. 3, 1991) (relevant provision currently codified at OMB Circular 

A-21, G, 8, a).

2578 Fed. Reg. 7282 (Feb. 1, 2013).

26This Council included NIH and other federal agencies. It reviewed issues related to the 

application of OMB Circular No. A-21 for federally sponsored research at universities, 

including the administrative burden associated with current policies and costs. Specifically, 

the Council solicited comments from stakeholders and provided various recommendations 

to OMB for consideration in its proposed revisions.

27The proposed revision would include the costs of certain computing devices as 

allowable direct costs.

Proposed Changes to OMB 

Circular No. A-21
 

Page 11 GAO-13-760 NIH Indirect Cost Funding

From fiscal year 2002 to fiscal year 2012, NIH reimbursements to 

universities for indirect costs associated with NIH-funded extramural 

research increased at a slightly faster rate than those for direct costs, and 

during some portions of this period indirect cost growth increased notably 

faster than direct cost growth. In fiscal year 2012, the 50 universities with 

the largest research programs received over two thirds of total indirect 

cost reimbursement. Higher indirect cost rates tended to be associated 

with universities located in high-cost-of-living areas and privately owned 

universities.

Reimbursements for indirect costs from fiscal year 2002 through fiscal 

year 2012 increased slightly faster than reimbursements for direct costs, 

but increased notably faster during some periods. Over this period, NIH 

reimbursements for indirect costs grew by about 28.1 percent, from 

$3.6 billion to $4.6 billion.28

 

28Our analysis generally focused on the relative differences between changes for indirect 

cost reimbursements and direct cost reimbursements. Therefore, we do not adjust the 

changes in reimbursements for inflation. Percentages are calculated based on the total 

amounts of reimbursement reported by NIH; the amounts of reimbursements in our 

narrative are rounded.

Over the same period, NIH reimbursement for 

direct costs grew by about 27.0 percent, from $9 billion to $11.5 billion. 

However, because there were large differences between indirect and 

direct growth in some years, indirect cost reimbursements increased 

notably faster than direct cost reimbursements during some periods. For 

example, from fiscal year 2002 to 2003, the first year of this period, there 

was a large increase in direct costs that compensated for greater growth 

in indirect costs during other years. As a result, from fiscal year 2003 to 

2012 indirect costs increased 16.9 percent, from about $3.9 billion to 

$4.6 billion, while direct costs increased 11.7 percent, from about 

$10.3 billion to $11.5 billion. Furthermore, in 6 of the 10 years, 

reimbursements for indirect costs increased relative to those for direct 

costs, by either increasing at a faster rate or declining at a slower rate. 

After fiscal year 2005, annual changes in reimbursements were generally 

small but consistent, with reimbursements for indirect costs increasing 

relative to direct costs in 5 of 7 years. (See fig. 2 for more details on the 

annual change in costs.)

From 2002 to 2012, 

NIH Indirect Cost 

Reimbursements to 

Universities Increased 

Faster than for Direct 

Costs, with Most 

Going to a Small 

Number of 

Universities 

From 2002 to 2012, 

Reimbursements for 

Indirect Costs Increased 

Slightly Faster than Those 

for Direct Costs, but 

Increased Notably Faster 

During Some Periods
 

Page 12 GAO-13-760 NIH Indirect Cost Funding

Figure 2: Percent Change from the Prior Year in Reimbursement for Direct and Indirect Costs, Fiscal Year 2003 to Fiscal Year 

2012

NIH officials noted that, historically, NIH’s reimbursements for indirect 

costs have remained a stable percentage of NIH’s total funding for all NIH 

awards overall. Our analysis specifically for university research, which 

accounted for almost two-thirds of NIH’s funding for extramural research 

in fiscal year 2012, indicates that in 2003 about 27.7 percent of NIH 

reimbursement for university research was for indirect costs, and in 2012 

this percentage increased slightly to 28.6 percent. This occurred while 

NIH’s budget for extramural research conducted at universities—which 

needs to cover both the direct and the indirect costs of research—slowed 

in the last few years. For example, during the most recent 5 years (fiscal

year 2008 to fiscal year 2012), NIH’s total funding for extramural research 

conducted at universities increased about 5 percent, whereas it had 
 

Page 13 GAO-13-760 NIH Indirect Cost Funding

increased about 21 percent in the 5 previous years (fiscal year 2002 to 

fiscal year 2007).29

In fiscal year 2012, almost 70 percent of NIH indirect cost reimbursement 

to universities was provided to about 10 percent of the universities (50 of 

a total of about 500) receiving NIH funding for extramural research.30

Indirect cost rates varied among these top 50 universities with the largest 

research programs, and the highest indirect cost rates were for privately 

owned universities and those located in high-cost-of-living areas. The 

indirect cost rates among the 50 universities ranged from 46.5 percent to 

69.5 percent.

(See app. I for the indirect cost reimbursements for these top 50 

universities.) These top 50 universities had the largest research 

programs, as defined by the largest amount of reimbursement for direct 

costs and a relatively large number of research grants.

31 For the top 50 universities, higher indirect cost rates 

tended to be associated with universities in high-cost-of-living areas32

 

29This change in reimbursement for extramural research includes only research grants 

awarded to universities, and does not include training grants.

and 

privately owned universities. For example, 8 of the 10 universities with the 

highest indirect cost rates were in areas with above-average costs of 

living, and 9 of the 10 universities with the highest rates were private. 

Some stakeholders reported several other factors that may be associated 

with variation of indirect cost rates among the top universities, including 

whether a university had a medical school or was receiving a utility cost 

According to NIH officials, the difference between the increases in direct and indirect costs 

during the period from fiscal year 2002 to fiscal year 2007 and the increases in these 

costs from fiscal year 2008 to fiscal year 2012 was due in part to NIH’s budget doubling in 

fiscal years 1999 through 2003.

30NIH provided direct and indirect cost data for 802 universities that received extramural 

research funding from fiscal year 2002 to 2012.

31Indirect cost rates for 5 universities out of the top 50 were not available from DCA.

32We measured local cost of living using the U.S. Census Bureau’s “cost of living index” 

for 2010, which measures relative price levels of consumer goods and services in 

participating areas at a single point in time. Localities get a score between 82.8 and 216.7; 

the higher the score, the higher the cost of living. We defined high cost of living as an 

index of greater than 120.

In 2012 the 50 Universities 

with the Largest Research 

Programs Received Most 

of the Indirect Cost 

Reimbursements
 

Page 14 GAO-13-760 NIH Indirect Cost Funding

adjustment.33 Table 1 shows the characteristics of the 10 universities with 

the highest indirect cost rates among the 50 universities receiving the 

highest amounts of indirect cost reimbursement in fiscal year 2012. 

Among the 10 universities in the table, those with the highest indirect cost 

rates were Mount Sinai Medical School and New York University School 

of Medicine; Johns Hopkins University and Yale University had the largest 

research programs as measured by the number of NIH grants awarded.

 

33Certain universities are eligible for a rate increase of 1.3 percent to account for the cost 

of utilities. This rate increase is known as the utility cost adjustment.
 

Page 15 GAO-13-760 NIH Indirect Cost Funding

Table 1: Characteristics of the 10 Universities with the Highest Indirect Cost Rates among the 50 Universities Receiving the 

Highest Amounts of Indirect Cost Reimbursement, Fiscal Year 2012

University

Final 

negotiated 

indirect cost 

rate (%)

Amount of 

indirect cost 

reimbursement 

($millions)

Number of 

NIH grant 

awards

Cost of 

living 

indexa Type of 

institution 

University 

is or has a 

medical 

school 

(yes or no)

Eligible for 

the utility 

cost 

adjustmentb

(yes or no)

Mount Sinai School 

of Medicine

69.5% $55.3 380 216.7 Private Yes Yes

New York 

University School of 

Medicine

69.5 54.5 344 216.7 Private Yes Yes

Weill Medical 

College of Cornell 

University

69.0 35.6 257 216.7 Private Yes Yes

Albert Einstein 

College of 

Medicine, Yeshiva 

University

66.0 53.1 353 159.0 Private Yes Yes

Yale University 65.6 114.1 839 122.1 Private Yes Yes

University of 

Massachusetts 

Medical School, 

Worcester

64.5 44.3 335 103.3 Public Yes Yes

Boston University 

Medical Campus

63.5 29.1 241 132.5 Private Yes Yes

University of 

Southern California

63.0 56.4 352 136.4 Private Yes Yes

Johns Hopkins 

University

62.0 171.8 1,227 119.2 Private Yes Yes

Harvard University 61.5% $55.1 111 132.5 Private Yes Yes

Source: GAO analysis of NIH and Division of Cost Allocation (DCA) data.

a

We measured local cost of living using the U.S. Census Bureau’s “cost of living index” for 2010, 

which measures relative price levels of consumer goods and services in participating areas at a 

single point in time. Localities get a score between 82.8 and 216.7; the higher the score, the higher 

the cost of living.

b

Certain universities are eligible for a rate increase of 1.3 percent to account for the cost of utilities. 

This rate increase is known as the utility cost adjustment.
 

Page 16 GAO-13-760 NIH Indirect Cost Funding

Stakeholders—university officials, DCA officials, and others—whom we 

interviewed identified several key factors that may lead to increases in 

reimbursements for indirect costs provided to universities. Some factors 

are related to the facilities costs, and others are related to administrative 

costs. NIH has not assessed the potential impact of future increases in 

indirect costs on its research mission, including planning for how to deal 

with these potential increases.

Some stakeholders underscored the importance to the research effort of 

providing funding for the costs of facilities. They explained that 

reimbursements for the facilities component of indirect costs—such as the 

amount of reimbursable square footage, operations and maintenance, 

building depreciation, and interest costs—help to support research 

innovation by providing funding for the development and maintenance of 

state-of-the-art research facilities. Some university officials we 

interviewed noted that these research facilities are necessary for 

conducting innovative biomedical research, such as research devoted to 

the role of genetic mutation for breast cancer that uses advanced lab 

space and equipment. They also noted that costs for these facilities have 

increased over time as biomedical research has become increasingly 

sophisticated. For example, a university’s officials stated that from fiscal 

year 2002 to fiscal year 2009, the cost of its facilities to support 

research—including those used to support advancement in data and 

computing—has grown from about $88 million to about $145 million.

DCA officials stated that the uncapped facilities component of the indirect 

cost rate provides universities few, if any, incentives for controlling these 

potentially increasing costs. For example, DCA officials noted that there is 

no limit on reimbursement for interest costs under the facilities 

component. DCA officials stated that while reimbursements for interest 

costs may allow universities to support needed renovations or 

construction of new facilities, the fact that these reimbursements are not 

capped may also encourage universities to borrow money to build new 

Stakeholders 

Identified Factors 

Related to Facilities 

and Administrative 

Costs That May 

Increase 

Reimbursements for 

Indirect Costs, but 

NIH Has Not Assessed 

Their Potential 

Impact 

Uncapped Facilities 

Component of the Indirect 

Cost Rate Provides Few, If 

Any, Incentives to Control 

Costs 
 

Page 17 GAO-13-760 NIH Indirect Cost Funding

facilities, which could lead to the building of more new space than is 

necessary for research needs. Officials also noted that these interest 

costs are out of DCA’s control and may vary. For example, at the time of 

our work, interest rates—which are used to determine interest costs—

were very low, but they could increase over time, which could increase 

costs for ongoing building projects or buildings that have already been 

completed, regardless of future building decisions by universities. 

Because of this factor, the indirect cost rate could be expected to 

increase, resulting in a potential increase in the amount of indirect cost 

reimbursements provided by NIH.

In addition, some stakeholders noted that, at the time of our work, 65 of 

about 500 universities receiving reimbursement for indirect costs in fiscal 

year 2012 were eligible for a rate increase of 1.3 percent to account for 

the higher cost of utilities.34 DCA officials added that OMB’s proposed 

revisions to Circular No. A-21 would allow all universities to receive some 

reimbursement for utility costs based on a revised formula. As a result, 

NIH reimbursements for indirect costs could be expected to increase as 

more universities would be eligible to include this cost in their indirect cost 

rates.

Some stakeholders noted that while the cap on the reimbursement rate 

for administrative costs—26 percent—helps to control reimbursements for 

indirect costs, it does not account for the recent increases in 

administrative costs reportedly incurred by universities. For example, 

university officials explained that their administrative costs have increased 

in order to comply with recent changes in regulatory reporting 

requirements, such as those related to reporting conflicts of interest. 

Some university officials explained that they have hired additional full-time 

staff to review and manage various reporting requirements as well as 

invested in additional information technology (IT) to support new software 

 

34The utility cost adjustment was implemented in 1998 to replace a system of special 

utility cost studies. It was made available to 65 institutions identified in Exhibit B of OMB 

Circular No. A-21, based on whether they had submitted a special study in their most 

recent indirect cost rate proposal. Universities on the list receive this adjustment in 

addition to the utilities portion of indirect costs that a school negotiates based on its 

proposal. Although OMB Circular No. A-21 states that, beginning in July 2002, federal 

agencies must reevaluate periodically the eligibility of institutions to receive the utility cost 

adjustment, no changes have been made to the list since the utility cost adjustment was 

implemented in 1998, as we reported in 2010. 

Administrative Cap 

Controls Potential 

Increases in Cost 

Reimbursement due to 

Growth in Administrative 

Costs Incurred by 

Universities
 

Page 18 GAO-13-760 NIH Indirect Cost Funding

related to regulatory requirements. Additionally, some stakeholders noted 

that administrative costs also have increased due to trends in the way 

biomedical research is conducted, such as an increase in collaboration 

between universities in research studies and an increased use of IT for 

biomedical research. For example, some university officials explained that 

many biomedical research projects now use advanced technology—such 

as high-sequencing technology or imaging—that requires greater 

investment in computing resources by the university. Additionally, one 

university’s officials noted that the advancements in IT provide support for 

interconnectivity, complex data security and data privacy requirements, 

and requirements for long-term storage and maintenance of electronic 

data. According to university officials at another university, in some 

instances they may charge some advanced computing equipment as a 

direct cost because it is specifically related to research; however, in most 

instances these computing resources are included in the administrative 

component of the indirect cost rate.

According to DCA officials, if costs that are part of the capped 

administrative component increase significantly, indirect cost 

reimbursements overall could increase if universities begin to categorize 

some of the costs as part of the uncapped facilities component. 

Specifically, DCA officials explained that currently there is a provision in 

Circular No. A-21 that advises certain limits on changing the 

categorization of certain costs—such as those costs incurred by a 

university that are associated with increased use of information 

technology—from the administrative to the facilities component. However, 

they noted that the proposed revisions to Circular No. A-21 did not 

include such a provision. DCA officials stated that they may be limited in 

their ability to control increases in reimbursements associated with these 

categorization changes if this provision is removed and if university 

administrative costs continue to increase.

NIH has not assessed the potential impact of future increases in indirect 

costs on its research mission, including planning for how to deal with 

potential future increases of these costs. As we previously reported, NIH 

has a program to periodically identify, analyze, and manage significant 

risks to its objectives, strategy and mission.35

 

35See

NIH officials noted that they 

GAO-09-687. 

NIH Has Not Assessed the 

Potential Impact of 

Increases in Indirect Costs 

on Its Mission
 

Page 19 GAO-13-760 NIH Indirect Cost Funding

assess risks related to all extramural research funding as part of this 

program, and that this assessment does not specifically focus on indirect 

costs for universities. According to NIH officials, NIH has not conducted 

such planning because overall indirect costs have remained around 27 

percent of NIH’s total budget for all extramural research, and, in their 

opinion, future cost increases are unlikely to change this figure 

significantly in spite of factors that may contribute to increased indirect 

costs. 

Therefore, NIH officials stated that they do not anticipate the need to 

consider adjusting reimbursements for indirect costs for most grants 

below the amount determined by a university’s negotiated indirect cost 

rate, which would require a change in law or regulation.36 However, NIH 

officials told us that should indirect costs rise significantly, they may need 

to reduce the number of research projects, which have already been 

reduced in part because of budget limitations and increases in the direct 

costs of research. NIH noted that the reduced budget in fiscal year 2013 

resulted in 700 fewer individual research grants. Even at current levels, 

indirect costs constitute a significant portion of NIH’s budget at about 20 

percent. Therefore, over time, increases in indirect costs could cause 

further reductions in the number of research projects that NIH could 

support.

NIH has indicated that NIH funding for both the indirect and the direct 

costs of university research provides critical support for biomedical 

research, covering the indirect costs of operating a research institution 

and the direct costs of specific research projects. NIH faces uncertainty 

related to the potential impact of increasing indirect costs on its funding of 

future research. Among research grants to universities specifically, NIH’s 

indirect costs are increasing at a faster rate than direct costs. While 

changes in recent years have generally been small, annual changes in 

reimbursement for indirect costs have consistently increased relative to 

those for direct costs, by either increasing at a faster rate or declining at a 

slower rate. Further, this has occurred while the growth in NIH’s budget 

for extramural research has slowed in recent years, putting pressure on 

NIH to find ways to continue to maximize its support of innovative 

 

36As previously noted, while OMB Circular No. A-21 requires agencies to adhere to the 

negotiated rate while it is in effect, an agency may apply a different rate when required by 

law or regulation. (OMB Circular A-21, G,11, b.) 

Conclusions 
 

Page 20 GAO-13-760 NIH Indirect Cost Funding

biomedical research. Several factors are expected to contribute to future 

growth in indirect costs for NIH. These factors include that NIH’s current 

system of reimbursing indirect costs—through indirect cost rates for each 

university calculated according to OMB guidance—provides few, if any, 

incentives for universities to control facilities costs. At the same time, the 

cost of university facilities to support biomedical research is increasing 

over time, as cutting-edge research requires more advanced labs and 

equipment.

NIH has not made plans for options that might address these trends—in 

part because it views increases in indirect costs as having been modest. 

However, indirect costs already represent one-fifth of NIH’s overall budget 

and about one-quarter of NIH’s budget for extramural research. NIH has 

experienced small but consistent increases in indirect costs, and factors 

suggest that indirect costs could increase more quickly over time in the 

future. If so, such increases could have an effect over the long term on 

the number and size of research grants that could be funded, thus posing 

a risk to scientific discoveries and knowledge.

To help address the uncertainty NIH faces related to the potential impact 

of increasing indirect costs on its funding of future research, we 

recommend that the Director of NIH assess the impact of growth in 

indirect costs on its research mission, including, as necessary, planning 

for how to deal with potential future increases in indirect costs that could 

limit the amount of funding available for total research, including the direct 

costs of research projects.

We provided a draft of this report to HHS, and HHS provided written 

comments (reprinted in app. II). HHS also provided technical comments, 

which we incorporated as appropriate.

HHS indicated that it agreed with our recommendation and that NIH had 

already taken steps to implement it, but HHS disagreed with a number of 

our conclusions. Specifically, HHS stated that NIH assesses the impact of 

indirect costs through its annual budget projections, through planning and 

congressional justifications, and as part of its risk management program. 

The draft report acknowledged NIH’s efforts in assessing risk facing its 

extramural research program. However, NIH has not indicated how these 

actions would address our recommendation by assessing the potential 

ongoing impact of indirect costs for universities on its funding of future 

research. Moreover, NIH has not developed a plan for how to deal with 

Recommendation 

Agency Comments 

and Our Evaluation
 

Page 21 GAO-13-760 NIH Indirect Cost Funding

potential continuing increases in indirect costs for universities. Instead, 

HHS indicated that, in past years, increases in indirect costs have been 

proportionally consistent with increases in direct costs, and therefore, 

there is not an immediate risk to NIH’s research portfolio. While the draft 

report acknowledged that indirect costs have remained a stable 

percentage of NIH’s overall research costs, it also noted that, for 

universities—which received almost two-thirds of NIH’s funding for 

extramural research—indirect costs increased notably faster than direct 

costs during some recent periods. Further, as indicated in the draft report, 

there are multiple indications that, for universities, indirect costs are likely 

to increase at a faster rate in the future, so past stability may not be 

sustained in future years. We remain convinced that increases in indirect 

costs could have an effect over the long term on the number and size of 

research grants that could be funded, thus posing a risk to scientific 

discoveries and knowledge.

In addition, in its comments, HHS included an analysis of indirect costs 

over the past decade for its overall extramural research portfolio. This 

analysis was different from our analysis because it focused generally on 

extramural research rather than specifically on university research. As 

noted in the draft report, our research questions were focused specifically 

on universities. Moreover, as institutions of higher education, universities 

generally have a broader focus on education than research institutions.

Further, as noted in the draft report, universities are subject to OMB 

Circular No. A-21 and their administrative costs are capped, unlike other 

research institutions. Because of the unique issues that universities face, 

our analysis of indirect costs excluded nonuniversity research institutions 

to avoid the possibility of data from these other NIH grantees masking 

trends for universities, which are the recipients of the largest portion of 

NIH’s grant funding.

Finally, HHS stated that we did not provide an opportunity for the 

department to provide input on our review of NIH’s assessment of the 

potential impact of indirect costs on NIH’s research mission. We disagree

with this characterization. NIH provided input on this issue to us during 

three separate meetings. For all three meetings, we provided discussion 

questions in advance. During one of the meetings, we and NIH officials 

discussed the key facts that were to be included in the draft report, 

including this issue. In addition, we offered NIH officials the opportunity to 

provide additional information in writing, as appropriate.
 

Page 22 GAO-13-760 NIH Indirect Cost Funding

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

Secretary of the Department of Health and Human Services, the Director 

of the National Institutes of Health, and other interested parties. In 

addition, the report will be available at no charge on GAO’s website at 

http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-7114 or at kohnl@gao.gov. Contact points for our Office 

of Congressional Relations and Office of Public Affairs can be found on 

the last page of this report. Other major contributors to this report are 

listed in appendix III.

Sincerely yours,

Linda T. Kohn

Director, Health Care
Appendix I: Indirect Costs and Rates for the 

Top 50 National Institutes of Health—Funded 

Universities, Fiscal Year 2012

Page 23 GAO-13-760 NIH Indirect Cost Funding

University Reimbursement for indirect costs ($) Indirect cost rate (%)

Johns Hopkins University $171,842,189 62.0%

University of Pennsylvania 132,558,612 60.0

University of Michigan at Ann Arbor 128,851,678 55.5

University of California San Francisco 123,730,058 54.5

University of Pittsburgh at Pittsburgh 115,284,723 51.5

University of Washington 114,508,104 54.0

Yale University 114,126,199 65.5

University of California at San Diego 107,909,828 54.5

Stanford University 101,755,908 n/a

Duke University 101,094,258 57.0

Washington University 100,949,670 52.0

University of California Los Angeles 92,485,025 54.0

Vanderbilt University Medical Center 89,397,501 56.0

University of North Carolina Chapel Hill 89,328,438 48.0

Columbia University Health Sciences 88,890,770 60.0

Emory University 74,684,383 55.0

University of Minnesota Twin Cities 66,118,864 52.0

University of Wisconsin Madison 60,091,265 50.5

University of Southern California 56,436,393 63.0

Mount Sinai School of Medicine 55,349,423 69.5

Harvard Universitya 55,128,269 61.5

New York University School of Medicine 54,484,823 69.5

Albert Einstein College of Medicine, Yeshiva University 53,081,812 66.0

Oregon Health and Science University 51,944,196 54.0

University of Texas Southwestern Medical Center—Dallas 51,217,775 58.5

University of California Davis 50,658,691 53.5

University of Chicago 50,134,610 57.0

Baylor College of Medicine 48,366,907 56.5

University of Alabama at Birmingham 47,643,167 46.5

Northwestern University at Chicago 47,324,211 54.5

University of Texas MD Anderson Cancer Center 46,842,255 —b

Case Western Reserve University 46,746,052 57.0

University of Colorado Denver 46,231,183 53.0

University of Iowa 45,128,057 51.0

University of Massachusetts Medical School Worcester 44,347,569 64.5

Appendix I: Indirect Costs and Rates for the 

Top 50 National Institutes of Health—Funded 

Universities, Fiscal Year 2012
Appendix I: Indirect Costs and Rates for the 

Top 50 National Institutes of Health—Funded 

Universities, Fiscal Year 2012

Page 24 GAO-13-760 NIH Indirect Cost Funding

University Reimbursement for indirect costs ($) Indirect cost rate (%)

University of Rochester 43,942,735 54.5

Ohio State University 39,755,792 52.5

University of Illinois at Chicago 38,574,578 n/a

University of Maryland Baltimore 38,569,736 48.0

University of Utah 37,945,477 49.5

Weill Medical College of Cornell University 35,555,472 69.0

University of Miami School of Medicine 33,617,736 53.0

University of California Irvine 32,851,174 53.0

Indiana University—Purdue University at Indianapolis 32,389,023 55.0

Massachusetts Institute of Technology 31,992,836 n/a

University of Virginia Charlottesville 31,890,011 54.0

University of California Berkeley 30,868,910 53.5

Boston University Medical Campus 29,091,950 63.5

University of Florida 28,396,985 46.5

Cleveland Clinic Lerner College/Med-CWRU $26,451,255 n/a

Source: GAO analysis of NIH and Division of Cost Allocation (DCA) data.

Note:

n/a = not available: this institution does not negotiate its indirect cost rate with DCA.

a

Harvard University negotiates three separate rates—one for the university, one for its School of 

Public Health, and one for its Medical School. The information reported here is for the university.

b

While NIH classifies this institution as a university, it is classified by DCA as a hospital. Therefore, a 

rate is not available because hospitals have a different rate-setting process than universities.
Appendix II: Comments from the Department 

of Health and Human Services

Page 25 GAO-13-760 NIH Indirect Cost Funding

Appendix II: Comments from the Department 

of Health and Human Services
Appendix II: Comments from the Department 

of Health and Human Services

Page 26 GAO-13-760 NIH Indirect Cost Funding
Appendix II: Comments from the Department 

of Health and Human Services

Page 27 GAO-13-760 NIH Indirect Cost Funding
Appendix II: Comments from the Department 

of Health and Human Services

Page 28 GAO-13-760 NIH Indirect Cost Funding
Appendix II: Comments from the Department 

of Health and Human Services

Page 29 GAO-13-760 NIH Indirect Cost Funding
Appendix II: Comments from the Department 

of Health and Human Services

Page 30 GAO-13-760 NIH Indirect Cost Funding
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 31 GAO-13-760 NIH Indirect Cost Funding

Linda T. Kohn, (202) 512-7114 or kohnl@gao.gov

In addition to the contact named above, Will Simerl, Assistant Director; 

N. Rotimi Adebonojo; George Bogart; Amy Leone; and Roseanne Price 

made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Acknowledgments 

(291101)
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