COVID-19 Federal Guidance for Grant Applicants and Recipients

Update:

The Office of Management and Budget (OMB) released a memo (M-20-26) on June 18, 2020, reminding federal agencies that flexibilities previously afforded to federal award recipients expired in mid-June.

Memorandum M-20-26 provided for the extension of two items:

Allowability of Salaries and Other Project Activities has been extended through September 30, 2020.

OMB also clarifies that recipients should utilize all other available funding sources prior to utilizing federal funds in order to preserve federal funds for the post-shutdown research ramp-up.

Extension of Single Audit Submission has been extended through December 31, 2020.

As additional OMB guidance is released regarding COVID-era flexibilities, further updates will be published here.

Original Post 3/31/2020:

As COVID-19 continues to evolve and affect research institutions across the country and world, the Office of Management and Budget (OMB) issued a memorandum authorizing granting agencies to offer flexibility regarding proposal submission practices, post-award management activities and availability of funding for COVID-19 research. These administrative flexibilities are provided to grantees that have closed or had business activities hindered due to COVID-19. Entities may be asked to provide sponsors with documentation describing the effects of COVID-19 and the impact to research operations that necessitated these flexibilities.

Major granting agencies, such as the National Institutes of Health (NIH) and National Science Foundation (NSF), have issued updated guidance following OMB’s memorandum. Major components of this guidance include confirmation that:

Proposals that are submitted after the published deadline will be considered for acceptance on a case-by-case basis (NIH).
Prior approval for pre-award costs is waived for costs incurred beginning January 20, 2020, through the COVID-19 "public health emergency period" and prior to the effective date of the award (NIH).
Financial and programmatic reports will be accepted if submitted late provided that grantees provide notice to the sponsor, but this may delay subsequent funding (NIH).
Salary and stipends for research personnel can continue to be charged to research awards during this time as long as it is done in a manner consistent with institutional policy, including effort or payroll verification practices (NSF, NIH, DOD).
Nonrefundable travel and/or hotel costs for travel that is cancelled/delayed by COVID-19 can be charged to a research award in a manner that is consistent with institutional policy (NIH).
The completion and submission of the Single Audit can be delayed up to 12 months and still allow the grantee to qualify as a "low-risk auditee" (NIH).
Awarding agencies are allowed to extend indirect rate proposal and extension request deadlines, permit grantees to delay completion or submission of their Single Audit Reports and relax System for Award Management (SAM) registration requirements for proposers and entities with existing registrations due to expire (OMB).

Grantee organizations should continue to take advantage of the flexibility afforded via waived prior approval requirements and expanded authorities.

Huron is monitoring any development in guidance from the OMB, NIH, NSF and other federal sponsors, as well as how institutions across the country are responding. We will continue to work with institutions to manage the impact to research operations and provide the research community with updates as this situation evolves.

We’ve created a quick guide of existing federal guidance for your use. This quick guide summarizes federal guidance available as of March 31, 2020. Please continue to refer to specific agency guidance and institutional directives as you plan your response.

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Federal Guidance Links:

OMB