TLDR
Modified Total Direct Costs (MTDC) is the standardized direct-cost base under 2 CFR 200.1 against which a nonprofit applies its indirect cost rate on federal awards. Starting with total direct costs, you subtract equipment, capital expenditures, patient care, tuition remission, off-site rental, scholarships and fellowships, participant support, and sub-award amounts above the first $25,000 per subcontract. Using the wrong base is a common single-audit finding.
Modified Total Direct Costs (MTDC) is the standardized direct-cost base under 2 CFR 200.1 against which a nonprofit applies its indirect cost rate on federal awards. Starting with total direct costs, you subtract equipment, capital expenditures, patient care, tuition remission, off-site rental, scholarships and fellowships, participant support, and sub-award amounts above the first $25,000 per subcontract. Using the wrong base is a common single-audit finding.
Plain-language definition
MTDC is the slice of direct costs you are allowed to multiply by your indirect cost rate. It is not total direct costs. OMB removes categories where loading overhead would be distorting — a single piece of equipment, a large sub-award, a scholarship — and leaves the remainder. The rate (10% de minimis or a negotiated NICRA) is applied only to that remainder.
Detailed definition
Under 2 CFR 200.1, MTDC equals all direct salaries and wages, applicable fringe benefits, materials, supplies, services, travel, and the first $25,000 of each sub-award or subcontract, minus the following mandatory exclusions:
- Equipment — tangible property with a useful life over one year and per-unit cost at or above the capitalization threshold (generally $5,000).
- Capital expenditures — building, land, and major improvements.
- Patient care charges — direct charges for hospital or clinic services to individuals.
- Tuition remission — tuition waived for employee-students under institutional policy.
- Rental costs for off-site facilities — rent on space leased outside the organization’s main operating location.
- Scholarships and fellowships — payments to students for study or research.
- Participant support costs — stipends, travel, and registration for non-employee participants in conferences or training.
- Sub-award amounts above $25,000 per subcontract — the first $25,000 of each sub-award stays in MTDC; the remainder is excluded. Flow-through funds that a pass-through entity moves to subrecipients beyond that $25,000 are also excluded, preventing indirect cost compounding across recipient layers.
The base applies whether the recipient uses the 10% de minimis rate under 2 CFR 200.414(f) or a negotiated rate under a NICRA, unless the NICRA explicitly specifies a different base.
How it works
Consider a $400,000 federal award with the following direct cost budget:
- Personnel: $180,000
- Fringe benefits: $45,000
- Supplies: $25,000
- Travel: $10,000
- Equipment (one server, $8,000): $8,000
- Participant stipends: $12,000
- Sub-award A: $60,000
- Sub-award B: $60,000
- Total direct costs: $400,000
MTDC calculation:
- Start: $400,000
- Exclude equipment: −$8,000
- Exclude participant support: −$12,000
- Exclude sub-award A above $25,000: −$35,000
- Exclude sub-award B above $25,000: −$35,000
- MTDC = $310,000
Applying the 10% de minimis rate: indirect = $31,000. Applying an approved 18% NICRA rate to the same MTDC: indirect = $55,800. Applying 18% to the full $400,000 instead — a common error — would overclaim indirect costs by $16,200 and produce an audit finding.
Related terms
- Indirect cost rate — the percentage applied to MTDC to recover overhead.
- Negotiated Indirect Cost Rate Agreement (NICRA) — the formal federal agreement establishing a nonprofit’s approved indirect rate and base.
- De minimis rate — the 10% rate under 2 CFR 200.414(f) available without negotiation.
- Sub-award — governed by 2 CFR 200.331 and 200.332; only the first $25,000 per sub-award counts toward MTDC.
- Pass-through entity — the prime recipient responsible for monitoring sub-awards and excluding flow-through funds from its own MTDC.
- Uniform Guidance — 2 CFR 200, the regulation defining MTDC.
Common audit findings
Single audits routinely flag MTDC errors. The four most common:
- Applying the rate to total direct costs. Recipients multiply their indirect rate by the full direct budget, forgetting to remove equipment and sub-award overruns. Overclaims get questioned and returned.
- Including the full sub-award. Finance teams include entire $100,000 sub-awards in MTDC instead of stopping at $25,000 per sub-award. The excess indirect is disallowed.
- Treating equipment below threshold as excluded. Only items at or above the capitalization threshold (typically $5,000) are equipment; smaller items remain in MTDC. Excluding them understates recovery.
- Missing participant support. Stipends and registration fees paid on behalf of training participants are excluded, but recipients frequently leave them in MTDC because they sit in the same budget category as supplies.
The AICPA Audit Guide Not-for-Profit Entities lists indirect cost base calculation as a standing testing area for Uniform Guidance compliance audits.
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Source: U.S. Government Accountability Office, Single Audit reports
Source: Urban Institute, National Center for Charitable Statistics
- Equipment (capitalization threshold)
- Tangible personal property with a useful life of more than one year and a per-unit acquisition cost at or above the organization's capitalization threshold, generally $5,000 per 2 CFR 200.1.
DEFINITION
- Sub-award
- An award of financial assistance from a pass-through entity to a subrecipient for carrying out part of a federal program, governed by 2 CFR 200.331 and 200.332.
DEFINITION
- Participant support costs
- Direct costs for items such as stipends, subsistence allowances, travel, and registration fees paid to or on behalf of participants or trainees — not employees — in connection with conferences or training projects.
DEFINITION
Q&A
What is the MTDC base?
MTDC is total direct costs minus a fixed list of exclusions defined at 2 CFR 200.1: equipment, capital expenditures, patient care, tuition remission, off-site rental, scholarships and fellowships, participant support, and sub-award amounts above the first $25,000 per subcontract.
Q&A
Why does MTDC exclude sub-awards past $25,000?
OMB caps the sub-award contribution to MTDC at $25,000 per subcontract to prevent indirect costs from compounding when funds pass through multiple recipients. The prime recipient recovers indirect on the first $25,000 only; the subrecipient recovers indirect on its own MTDC base.
Q&A
Is MTDC required for the 10% de minimis rate?
Yes. 2 CFR 200.414(f) specifies that the 10% de minimis rate must be applied to MTDC, not to total direct costs. Applying it to total direct costs overstates indirect recovery and is a common audit finding.
Q&A
Can a NICRA use a base other than MTDC?
Yes. A NICRA may specify a different indirect cost base — such as total direct salaries and wages, or total direct costs less specific items — but the MTDC definition controls unless the NICRA explicitly overrides it.
Frequently asked