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  • Jordan

    Member
    August 5, 2026 at 1:30 pm in reply to: Inconsistent IRS Guidance on Conflicts of Interest

    This is an important distinction that many nonprofit leaders may overlook, especially when relying on standard IRS guidance for governance policies. Organizations should view the IRS sample conflict of interest policy as a starting point while ensuring their policies address broader statutory requirements and sector-specific risks. It would be valuable to hear how other nonprofit professionals have adapted their conflict of interest frameworks to address this difference in practice.

  • Jordan

    Member
    August 4, 2026 at 7:07 pm in reply to: Session 3: Using Financial Information to Make Strategic Decisions

    I would appreciate having a link to the recorded session.

  • Jordan

    Member
    August 2, 2026 at 12:38 pm in reply to:

    To access large unexpected gifts, we built a realistic multi-year budget, strengthened financial reporting/reserves, and showed measurable programmatic impact.

  • Jordan

    Member
    August 1, 2026 at 7:17 am in reply to: NCN Executive Order Summary

    Most parts of the executive order are pretty cool. I don’t think we will have any issue with that from our end.

  • Jordan

    Member
    July 31, 2026 at 8:00 am in reply to: Applying for an indirect cost rate (ICR) for federal awards

    Yes, we went through this some years ago (established a NICRA with our cognizant agency). A few things that helped:

    • Confirm your cognizant agency first: for most nonprofits it’s HHS (Division of Cost Allocation) or your largest federal funder if HHS isn’t it. This determines who you’re actually negotiating with.
    • 2 CFR 200 Appendix IV is your bible for allowable methodology. Read it before you draft anything.
    • Decide between a provisional/final rate vs. the 10% de minimis: if your indirect costs are much higher than 10%, it’s worth the lift; if you’re borderline, de minimis may not be worth the paperwork.
    • You’ll need a solid cost allocation plan and a clean base. Get your base definition right early; it drives everything downstream.
    • HHS has a decent indirect cost rate proposal checklist and sample formats on the DCA website; use their template rather than building from scratch.
    • Budget for it taking 3–6 months minimum from submission to negotiated agreement, sometimes longer if there’s back-and-forth.
    • If you have the budget, a consultant who’s done NICRA negotiations before can save you multiple rounds of revisions. HHS reviewers are picky about base/pool consistency.

    Happy to share the checklist we used if that would help

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