RE: Your indirect cost rate

Clean, defensible indirect cost rate proposals — built by the person who used to review them.

A decade negotiating and auditing federal indirect cost rates, now on your side of the table. Packages a reviewer can follow in minutes, not days.

FULL COST RECOVERY · NEGOTIATED & DEFENSIBLE · NA NEEDICR.COM
Experience
10 yrs, Federal Negotiator & Auditor
Agreements negotiated
Up to $3 billion
Rulebooks
2 CFR 200 · FAR 31
Sectors
Nonprofit · Commercial · Gov
Sec. 1 — Services

Four ways we put a defensible rate to work for you.

Whether you've never had a negotiated rate or you're tired of leaving recovery on the table, our indirect cost rate consulting comes down to the same work: get the numbers right, document them so they hold, and make the case to your cognizant agency.

1.1Indirect cost rate proposalsPreparation
1.2Rate negotiation supportNegotiation
1.3Audit readiness & reviewDefense
1.4Training courses & materialsTraining
1.1

Indirect cost rate proposals

Full proposal preparation — cost pools, allocation bases, and the schedules your cognizant agency expects. We assemble the package so it's reviewer-ready the first time, not after three rounds of questions.

1.2

Rate negotiation support

We sit with you through negotiation and finalization. Because we've been the negotiator, we know which adjustments hold up, which costs draw scrutiny, and how to keep your provisional and final rates consistent.

1.3

Audit readiness & review

Already have a NICRA or de minimis election? We pressure-test your allocation methodology, unallowable cost treatment, and documentation before an auditor does — and fix what won't survive review.

1.4

Training courses & materials

Practical training for finance and program staff — cost principles, allowable vs. unallowable costs, MTDC, and the rate types that come up most: provisional, final, predetermined, and fixed with carry-forward. Live workshops or materials your team keeps.

Sec. 2 — The real problem

Negotiations rarely drag on because the rate is unreasonable.

They drag on because the proposal is overloaded, overly complex, and structured in a way that makes review harder than it should be. We've watched negotiations stretch by months for exactly that reason — and it's avoidable.

2.1

Data overload

Dumping every possible schedule and narrative at once buries the few items that actually drive the rate decision.

2.2

Structure that hides the story

Unnecessary sections and inconsistent roll-ups make it hard for the reviewer to trace the logic from costs to pools to bases to rate.

2.3

Rework and delay

When the reviewer can't quickly validate the "why," they ask for more — extending negotiation and consuming your team's bandwidth.

2.4

Higher cost, more risk

Complex submissions cost more to build and defend — and they make it easier for definitions to be misread, turning small ambiguities into avoidable disputes.

Clear traceability beats volume. The reviewer should be able to follow the logic in minutes, not days. A tighter package reduces questions, reduces cost, and shortens the cycle.

Self-service Wondering what your gap is? Run your own numbers → Or score your grant readiness in 12 questions →

Sec. 3 — Who we serve

Three sectors, two rulebooks, one goal: full, defensible recovery.

The cost principles that govern your rate depend on what kind of organization you are. We work in all of them.

2 CFR 200, Subpart E

Non-Profit Organizations

  • First-time negotiated indirect cost rate (NICRA) proposals
  • De minimis (15% MTDC) vs. negotiated rate analysis
  • Indirect cost recovery on federal grants & awards
  • Allowable vs. unallowable cost reviews
FAR Part 31

Government Contractors

  • Overhead, fringe, and G&A rate structures
  • Final & provisional billing rates
  • Incurred cost submissions & rate true-ups
  • FAR 31.205 unallowable cost screening
2 CFR 200, Subpart E

State, Local & Tribal

  • Department & statewide indirect cost rate proposals
  • Provisional, final, predetermined & fixed-with-carry-forward rates
  • Rate true-ups and carry-forward reconciliation
  • Cognizant agency coordination & negotiation
Sec. 4 — Process

A straight line from "no rate" to "negotiated and defensible."

4.1

Assess

We review your financials, awards, and current treatment to find the right rate structure and what you're recovering today.

4.2

Build

We construct the cost pools, allocation bases, and schedules — and document the methodology so it holds up to review.

4.3

Negotiate

We submit to your cognizant agency and work the negotiation through to a signed rate agreement.

4.4

Sustain

We keep provisional and final rates accurate year to year and train your team to maintain the rate themselves.

Sec. 5 — About the negotiator

You're hiring the person who used to review proposals like yours.

Most consultants learned indirect cost rates from the outside. I spent a decade inside the process — negotiating rates and auditing proposals for the federal government, on agreements up to $3 billion. I know exactly where reviewers push back, which costs trigger questions, and what documentation actually survives an audit.

That experience changes the work. I don't submit a proposal and hope. I build it the way I'd have wanted to receive it — clean, supported, and ready to negotiate.

  • Former federal rate negotiator and auditor
  • Fluent in both 2 CFR 200 and FAR Part 31
  • Proposals built reviewer-ready, not draft-ready
  • Provisional-to-final rate consistency built in
  • Training so your team isn't dependent forever
T. Pisarenko
Tony Pisarenko · NICRA Advisors
USMC veteran · former federal rate negotiator & auditor

Book a free 30-minute consultation →

Tony Pisarenko, founder of NICRA Advisors and former federal indirect cost rate negotiator and auditor
Fig. 1 — T. Pisarenko
Former federal rate negotiator & auditor
Sec. 6 — Common questions

What organizations ask before they start.

Should I just take the 15% de minimis rate instead of negotiating?

Sometimes — it's simple and requires no documentation. But for many organizations the de minimis rate (15% of modified total direct costs) recovers far less than a negotiated rate would. We run the comparison so the decision is based on your actual numbers, not a default.

We've never had a negotiated rate. Where do we even begin?

That's the most common starting point. We assess your financials and awards, determine your cognizant agency, and build the first proposal from scratch — then walk it through negotiation to a signed rate agreement.

What's the difference between 2 CFR 200 and FAR Part 31?

They're the two cost-principle frameworks. Non-profits and state, local, and tribal governments fall under 2 CFR 200, Subpart E. Commercial and for-profit contractors fall under FAR Part 31. The rate mechanics differ in each — we work in both.

Do you only prepare proposals, or do you train our team too?

Both. We prepare and negotiate proposals, and we offer training courses and materials so your finance and program staff understand cost principles, allowable costs, and rate mechanics well enough to maintain the rate going forward.

Can you review a rate or NICRA we already have?

Yes. We pressure-test existing rates, allocation methodologies, and documentation for audit risk — and fix what won't hold up before a reviewer finds it.

What does an engagement cost?

Fixed fee, scoped after the free consultation — sized to your organization and the state of your records, not open-ended hourly billing. In most cases the de minimis vs. negotiated comparison makes the economics clear before you commit to anything.

How long until we have a negotiated rate?

Building a reviewer-ready proposal typically takes a few weeks once your records are in hand. The negotiation itself runs on your cognizant agency's clock and can take months — which is exactly why the package matters: a proposal the reviewer can trace quickly is the single biggest factor you control.

Get started

Whether it's your first proposal or your last negotiation dragged on — the package decides how it goes.

Never had a negotiated rate? We build the first proposal from scratch and walk it through to a signed agreement. Tired of rounds of reviewer questions? We simplify the package, improve traceability, and shorten the cycle.