Updated Guidance from OMB, NIH, NSF, DOD, USAMRAA
The Office of Sponsored Research has been closely monitoring updates from our sponsors on proposal and award management concerns with regards to COVID-19. The Council on Government Relations (COGR) is another resource that provides guidance links on federal agencies and Frequently Asked Questions Regarding COVID-19’s Impact on Federal Awards.
OSR continues to monitor for guidance and below are key recent updates:
OMB – Managing Federal Contract Performance Issues Associated with the Novel Coronavirus (COVID-19)
The Office of Management and Budget (OMB) issued three memos to federal agencies regarding managing federal contract performance issues with COVID-19.
- Memo M-20-11 allows federal agencies to implement flexibilities initially for COVID-related activities
- Memo M-20-17 allows agencies to provide additional flexibility to recipients affected by the loss of operational capacity and increased costs due to the COVID-19 crisis
- Memo M-20-18 provides additional guidance to further assist the acquisition workforce as it addresses impacts due to COVID-19
Flexibilities Available to Applicants and Recipients of Federal Financial Assistance Affected by COVID-19
In Notice NOT-OD-20-086, the National Institutes of Health (NIH) identified short-term administrative flexibilities to assist applicants with managing administrative, financial management and audit requirements under the Uniform Guidance. These flexibilities are applicable to NIH applicants and recipients where the entity is conducting research activities related to or affected by COVID-19.
Cost Related Flexibilities/Expenditure of Award Funds:
- Travel – Non-refundable costs associated with grant-related travel that has been cancelled due to COVID-19 may be charged to the NIH award if they would have otherwise been allowable. See NIH GPS 7.9.1 for detailed information on the allowability of travel expenses.
- Salaries – If a recipient organization’s policy allows for the charging of salaries and benefits during periods when no work is performed due to the effect of COVID-19, regardless of the funding source, including Federal and non-Federal, then such charges to NIH grant awards will be allowable. *UNC policy allows for 30 days administrative leave in this instance*
Guidance for NIH-funded Clinical Trials and Human Subjects Studies Affected by COVID-19
In Notice NOT-OD-20-087, NIH has provided guidance outlining the flexibilities available to recipients conducting NIH-funded clinical trials and human subject studies, that are impacted by the declared public health emergency for COVID-19.
Flexibilities for Assured Institutions for Activities of Institutional Animal Care and Use Committees (IACUCs) Due to COVID-19
In Notice NOT-OD-20–088, NIH informs institutions of flexibilities provided in the Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animals (Policy) that are applicable to implementing a pandemic plan for animal care and use programs. The PHS Policy also contains provisions that can be instituted as social distancing measures to prevent the spread of disease.
NSF Implementation to update OMB Memo M-20-17 and updated Frequently Asked Questions about the Coronavirus Disease 2019 (COVID-19) for NSF Proposers and Awardees
NSF recently issued Notice No.146 providing background for their updated memo and FAQs addressing questions associated with proposal submission and award management that may arise in relation to COVID-19. Given that COVID-19 and the associated impacts continue to evolve, proposers and awardees are strongly encouraged to monitor the NSF website for updates.
Allowability of Costs Flexibility:
- Travel – Recipients who incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to the public health emergency, are authorized to charge these costs to their award
- Salary – Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active NSF awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. *UNC policy allows for 30 days administrative leave in this instance*
NIH has also issued a separate Notice related to Late Application flexibilities and a COVID-19 Flexibilities for Applicants and Recipients FAQs for additional guidance.
Go to NSF OMB implementation Memo
Frequently Asked Questions for DOD Research Proposers and Awardees Impacted by the Novel Coronavirus (COVID-19)
The Department of Defense (DOD) is aware that many in the research community have been impacted by COVID-19. The DOD is taking action to provide greater flexibility to the research community in this challenging time. Based on the OMB Memorandum (listed above), please find below a link to answers to Frequently Asked Questions by grantees and proposers about research and development awards (grants and cooperative agreements) at the DOD.
Key Cost-Related Guidance::
Q: Can I get reimbursed for costs incurred due to travel cancelled b/o COVID-19?
A:The DOD will allow nonrefundable travel expenses incurred for travel canceled due to COVID-19 to be charged to active awards in agreement with OMB Memo M-20-17.
Q: Can I continue to charge salaries and benefits to currently-active awards for personnel who would normally be paid out of the award (e.g., graduate students, principal investigators, and postdoctoral researchers)?
A: Based on OMB Memo M-20-17 and the uniform guidance (2 CFR 200.403, 2 CFR 200.404, 2 CFR 200.405), the DOD will allow recipients to continue to charge salaries and benefits to currently-active awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal. *UNC policy allows for 30 days administrative leave in this instance*
USAMRAA COVID-19 FAQs on Grants and Cooperative Agreements
United States Army Medical Research Acquisition Activity (USAMRAA) published information on flexibilities for organizations funded by USAMRAA to conduct research on COVID-19 along with Frequently Asked Questions (FAQs) on other administrative flexibilities whose operations have been adversely impacted in the emergency response related to COVID-19.
Please contact your department’s Sponsored Projects Specialist or the Sponsored Programs Office with questions specific to your proposal and/or award.
Please contact ResAdminOSR@unc.edu for other general sponsored programs administration questions and requests.
The Office of the Vice Chancellor for Research also provides a response to COVID-19 that provides further resources for the campus research community.