Provisional OMB Guidance on Federal Research Affected by COVID-19 (19 March 2020)
This will be posted to the RII COVID-19 site, and updated as we receive more information. For questions about your grant account, please contact your Sponsored Projects & Contracting Services postaward team.
On March 19, the Office of Management & Budget (OMB) issued a memo to the heads of executive departments and federal agencies about their options to offer relief for recipients and applicants of federal financial assistance directly impacted by the Novel Coronavirus (COVID-19) due to loss of operations. The memo, and the one that preceded it (March 9, 2020), allows federal agencies additional flexibility in working with grant recipients affected by loss of operational capacity due to the COVID-19 pandemic.
So, what does this mean, and what happens next?
- This guidance is for federal agencies to consider, and pass down to grantees (or not). Individual agencies will decide how/if they will implement, and will issue their own guidance based on this memo. RII will post this guidance, as it comes in, to https://research.arizona.edu/covid19#collapse-212
- Agencies may extend end dates for competing applications and unsolicited applications.
Notice of Funding Opportunities
- Emergency funding opportunities may be issued with less than 30 days’ notice.
- Awards active as of March 31, 2020 with an end date up to December 31, 2020 may be extended by the agency for up to 12 months.
- For continuation requests due from April 1, 2020 to December 31, 2020, federal agencies may accept a brief statement from the recipient in lieu of a continuation application.
Allowability of salaries and other project activities
- Agencies can allow recipients to continue to charge salaries and benefits, consistent with our own local policy for paying salaries under unexpected or extraordinary circumstances, across all funding sources.
- Other costs necessary to resuming activities may also be allowed, if they are consistent with cost principles.
- Appropriate documentation of these costs will be required.
The University of Arizona’s policy for paying salaries under unexpected circumstances is consistent with this guidance. To date, only the NIH has indicated they will implement these cost allowability measures. Parts of the Department of Defense have indicated that salaries will not be allowed, but that information came out before the March 19 OMB memo.
Allowability of costs not normally allowed
- Costs for cancellation of events or travel, and costs related to restarting work may be allowed, but additional funds may not be available to continue the event or travel at a later time.
- Agencies may offer specific guidance on different cost items.
- Appropriate documentation of these costs may be required.
Prior Approval requirements
- Agencies may waive these.
Extension of progress, financial, and other reporting
- Extensions of up to 3 months may be allowed.