Post Last Updated 10/14/2020 – Most recent information is in the Just Posted! section
Knowledge Enterprise (KE) Research Operations is fully functional and operating at normal capacity. This includes all units within Office for Research and Sponsored Projects Administration (ORSPA) and Office of Research Integrity and Assurance (ORIA), are open for business. All ORSPA and ORIA staff are working remotely and able to assist via phone, email and Zoom.
Note: This site contains information, guidance and actions being taken in response to daily changes. It will continue being updated frequently as new information is received.
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JUST POSTED! (Any updates from the last two business days)
Guidance From the Office of Management & Budget (Section updated 10/14/2020 at 8:00 AM)
OMB memo M-20-26 expired on 9/30/2020. As a reminder, M-20-26 provided an extension to the salary charging flexibilities that were included in M-20-17. It allowed for recipients of grants and cooperative agreements to pay salaries and benefits of employees that could not work because of COVID-19 (e.g. because a facility was closed due to COVID-19). Now that this flexibility has ended, we have noticed federal agencies are posting guidance around requesting further extensions, where a majority are being reviewed on a case-by-case basis. ASU is fully operational (e.g. no facilities are closed due to COVID-19) and any extensions to the now expired flexibility should not be requested or necessary. If you have a particular situation where additional discussions is needed, please contact Heather Clark at Heather.Christina.Clark@asu.edu
Human Subjects (Section updated 10/9/2020 at 2:25 PM)
This section has been updated to clarify that starting Monday, October 5, all in-person visit(s)/face-to-face interaction with human subjects can resume, regardless of location (on-campus or off-campus location).
FREQUENTLY ASKED QUESTIONS & PAST UPDATES
- Award is either terminated in whole or part
- Award activities must stop (e.g. issued a stop-work order)
- Award activities must be suspended
- Award scope and price is being adjusted
- Check that the sponsor allows for the pay to continue if the employee is not able to contribute to the project. Visit the COGR COVID -19 Resource Page and the COGR Agency Guidance Matrix for sponsor specific information.
- If allowed, document the following for each affected project employee:
- Employee name
- Award number the employee is being paid from
- Sponsor name
- Description of the work the employee was performing
- Date the work could no longer be performed due to COVID-19 impact
- Reference/citation documenting that sponsor allows continued charging of personnel costs
- Date work could be resumed under the award (alert faculty to report this date for inclusion in documentation).
- Copy of ASU March 16, 2020 Novel Coronavirus (COVID-19) announcement which states in part,
- Be certain to inform the PI that while their sponsor may have a policy in place that allows for continued salary charging even if project staff are currently unable to work on project objectives, there is no indication that additional funding will be available to pay salaries and wages that are incurred after the shutdown ends or to provide for other unforeseen expenses.
Due to COVID-19, some international students and postdocs may be required to return home to a foreign country and work remotely. If you decide to employ these students to work remotely on a sponsored project additional sponsor and internal reviews and approvals are needed. These reviews and approvals are related to cost allowability, export control, Sponsor Program and/or Grant Officer approval. Each Sponsor (e.g. Federal agencies, non-profit, for-profit, etc.) are quite different in their positions on the allowability of salaries for students/postdocs working remotely from a foreign country. It is advised that if the student can work on the project, then students should be paid from the project. It is reasonable to support students and the associated costs (including tuition & stipends) would be allowable as the only change is physical location of the student. Obtaining written approval from the sponsor is necessary unless the sponsor has already issued written guidance addressing the issue.
NIH is one agency that does address in writing the foreign component, other agencies have not yet.
Please notify your Research Administrator and AMT Grant & Contract Officer of this foreign component. They will work with ASU’s Office of Research Integrity and Assurance (ORIA) and other offices to address potential matters raised by international remote work.
Potential matters include the following:
- Are there appropriate measures in place to safeguard data and work product?
- Documentation to address security of research access and results
- What country the student will be located?
- Type of work to be performed?
- Benefit of work to be performed, university and sponsor perspective?
- Review of sponsor award for any restrictions, notification and approvals needed
- Use the COVID-19 Department Reporting Worktag: EHS-VIRUS PREVENTION
- For cancelled conference/meetings, attach notification of change in conference/meeting (cancellation or change to virtual format) to the travel claim; if claim has already been processed, save the documentation in the appropriate account files
- Retain documentation from airline that cost is non-refundable and that there is a credit for future travel
- Copy of ASU March 13, 2020 Novel Coronavirus (COVID-19) announcement which states in part,
- Copy of Unit’s written notification to traveler who receives airline credit that they are expected to use the credit for future travel related to project
- Track airline credits on Unit spreadsheet to ensure that credit is used before expiration
Travel – ASU Issued Subawards (Section added 06/01/2020 at 2:00 PM)
For travel approved in the ASU Subaward, the Subawardee(s) may proceed with the travel and are subject to whatever policies are in place with their employer/educational institution.
Depending on the ASU sponsor, the PI/researcher could ask for explicit approval if needed. ASU’s policy prohibiting grant-funded research (e.g. sponsored project) travel remains in place and the policy on travel applies to ASU employees.
Will proposal submissions be impacted at this time? (Section added 3/19/2020 10:00 am)
ORSPA’s proposal submission process remains unchanged at this time. Units are advised that many proposal deadlines have changed in response to COVID-19. Many sponsors are not doing blanket extensions across all funding announcements and are extending deadlines differently by each opportunity. RAs are advised to continue to monitor Funding Opportunity Announcement (FOA) updates and advise PI(s) and the assigned Proposal GCO, as appropriate.
(3/20/2020 8:20 am) – It is more important than ever to make sure your assigned Proposal GCO is given ample time to submit each proposal in order to navigate any potential internet interruptions related to telework.
Due to the need to work remotely, will the F&A rate change to off-campus for my project(s)?
The rate will not change, we will continue to charge the current on-campus rates.
Current Guidance from the Office of Management & Budget (Section Updated 10/14/2020 at 8:00 AM)
This section has been updated to include recently issued guidance from the Office of Management & Budget.The RA community is encouraged to download and review the guidance issued by the OMB for the temporary administrative relief to recipients and applicants of federal assistance:
|Grants & Cooperative Agreements*||M-20-11 (Issued 03/09/2020)|
|Contracts||M-20-18 (Issued 03/20/2020)|
- Narrow scope
- Intended only for application to grantees who receive award funding specifically to address the COVID-19 pandemic
- Outlined flexibilities have no expiration date at this time
- “Awarding agencies may allow necessary pre-award costs that are incurred (i) from January 20, 2020 through the Public Health Emergency Period and (ii) prior to the effective date of a Federal award.”
- M-20-18 does not contain the same flexibilities as guidance issued for grants and cooperative agreements.
- Recipients of Federal contracts are required to submit a notification statement of the impact of the execution of contract to the awarding agency.
- RAs are encouraged to contact the contracting officer for clarifications on issues not addressed by M-20-18.
- Any allowed flexibility to continue to charge personnel costs on Federal contracts is aimed at “maintaining a state of readiness” to fulfill contractual commitments, it is not a mechanism to allow “charging of personnel idle time”.
- Broad scope
- Flexibilities applicable to all Federal grantees
- Outlined flexibilities expire after 90 days (June 17, 2020) but may be extended
- No additional flexibility allowed for pre-award costs
- Item 1 - Allowability of salaries and other project activities (item 6 in M-20-17), EXPIRED 09/30/20. OMB added restrictions to the flexibilities allowed in item 1, Allowability of salaries and other project activities by adding the following language:
- Item 2 - Extension of Single Audit Submission (item 13 in M-20-17). This item does not impact ASU as our FY2019 Single Audit has been released.
- M-20-26: Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations Download PDF (6/18/20) EXPIRED 9/30/2020
- M-20-23: Aligning Federal Agency Operations with the National Guidelines for Opening Up America Again Download PDF (4/20/20)
- M-20-22: Preserving the Resilience of the Federal Contracting Base in the Fight Against the Coronavirus Disease 2019 (COVID-19) Download PDF (4/17/20)
- M-20-21: Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19) Download PDF (4/10/20)
- M-20-20: Repurposing Existing Federal Financial Assistance Programs and Awards to Support the Emergency Response to the Novel Coronavirus (COVID-19) Download PDF (4/9/20) RESCINDED 6/18/2020
- M-20-18: Managing Federal Contract Performance Issues Associated with the Novel Coronoavirus (COVID-19) Download PDF (3/20/20)
- M-20-17: Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations Download PDF (3/19/20) RESCINDED 6/18/2020
- M-20-11: Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) Download PDF (3/9/20) EXPIRES 7/26/2020
- COGR’s Frequently Asked Questions Regarding COVID-19’s Impact on Federal Awards (Version 2.1) (3/31/20) has been revised to include updates to agency guidance.
- A FAQ Addendum with new FAQs that have been developed from questions from the membership which will be updated weekly as additional information becomes available.
- A Federal Agency Guidance Matrix with several major grant-making agencies that will be updated weekly as additional guidance becomes available. The information is current as of 3/31. We have also attached the Matrix in a locked Excel format for your reference.
- NIH FAQ Addendum #1 with new FAQs have been developed from NIH specific questions from the membership and will be updated periodically as new information becomes available (4/13/20)
- A Costing FAQ Addendum #2 has been developed from costing specific questions from the membership and will be updated as new information becomes available (4/9/20)
- A federal agency guidance matrix that is updated periodically as new guidance becomes available (4/8/20)
UIDP is forming a New organization: COVID-19 Healthcare Coalition
The COVID-19 Healthcare Coalition is a private sector response to coordinate collection, aggregation, and analysis of COVID-19 data and best practices. Mayo Clinic, Leavitt Partners and several MIT faculty leaders were among the first to form this effort and asked MITRE to help coordinate the real-time data analytics effort.
Any ASU faculty interested in participating should email Clay Arnett in the Office of Industry Research & Collaborations for more information.
- Prior approval requirement waivers (# 8) has been revised to update the specific situations that require NSF prior approval. Additional guidance also has been added for Major Facility Recipients;
- Extension of financial and other reporting (# 10) has been supplemented with information on the processing of payments via NSF’s Award Cash Management Service; and
- Extension of closeout (# 12) has new guidance extending award closeout from 120 days to 180 days.
- Impact on Existing Deadline Dates
- Frequently Asked Questions (FAQs) About the Coronavirus Disease 2019 (COVID-19) for NSF Proposers and Awardees – March 16, 2020
|A MESSAGE FROM JEAN FELDMAN, HEAD POLICY OFFICE, NATIONAL SCIENCE FOUNDATION|
- It rescinds some of the flexibilities outlined under NOT-OD-20-086, including direct charge of canceled travel and conference registration fees due to COVID-19 as well as the flexibility to repurpose/donate resources purchased with NIH grants (i.e. PPE).
- In line with the guidance provided by OMB’s M-20-26, it extends the allowability of continuing to charge salaries and benefits to active NIH awards consistent with ASU’s policies through 9/30/2020.
- It also continues to authorize recipients to charge other costs necessary to resume activities supported by the award.
- NIH may also evaluate the recipient’s ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances based on subsequent annual project reports and other communications with the recipient.
- Any requests for use of flexibilities specified in OMB Memoranda M-20-17 or M-20-20 that were submitted prior to June 16th are actionable by NIH as outlined in NIHs implementation.
|Conference Registration Fees||Non-refundable registration fees for conferences, symposiums or seminars that have been cancelled due to COVID19 may be charged to the NIH award if they would have otherwise been allowable (e.g. necessary to accomplish program objectives).||Non-refundable costs of cancelled conference registration fees allowable.||Charge non-refundable costs of cancelled conference registration fees to award.|
|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.||Non-refundable costs of cancelled travel allowable.||Charge non-refundable costs of cancelled travel to award.|
|Salaries||NIH understands that many researchers may be unable to work as a result of or related to the effects of COVID-19. 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. Reminder: NIH awarding Institutes/Centers (ICs) may request documentation to confirm the requirements of institutional policies.||Salaries during periods of inactivity allowable charges to award if non-sponsored accounts allow similar charges. Recurring salaries and leave pay disbursed by ASU remain allowable charges even if work is interrupted.||No changes in payroll mapping required for salaries paid by ASU during periods of inactivity.|
***These flexibilities are available IF the award is related to or affected by COVID-19. When asserting need and taking action to access requirement flexibility, thoroughly document qualifying circumstances and justification for need.Section Updated 06/30/2020 at 12:00PM) Can recipients donate Personal Protective Equipment (PPE) and supplies acquired with NIH grant funds to local hospitals and health care facilities in support of COVID-19 efforts? Yes, though 06/16/2020 only, recipients may donate PPE and other lab supplies in support of efforts related to COVID-19. Recipients may re-budget grant funds to repurchase supplies at a later date, use large unobligated balances, or submit an administrative supplement request to the funding IC for consideration. Note that NIH will review such requests to determine whether the initial costs were made to directly support the project or were indirect costs. NIH can only provide additional funds to support supplies that are directly charged to the project(s). Recipients may negotiate rate agreements with HHS Cost Allocation Services to account for increased indirect costs specific to the effects of COVID-19.
- Blackout period: April 30 - May 15, 2020
- Recipient training: May 13 - 14, 2020
- Service Transition: May 14 - 15, 2020
- Service Go-Live! Awards processing resumes: May 18, 2020
- With the fiscal year 2021 funding applications open, and limited staff in the office, we understand that it could be difficult for some LEAs to meet the May 1st application due date.
- We have adjusted our policy regarding for FY21 substantial approvals. If your grant is submitted prior to July 1st and your GSA has been accepted, the grant will be given substantial approval. If substantial approval occurs by this date, your LEA may begin obligating funds on July 1, 2020.
- Grants must be in Director Approved status before an LEA can begin to draw down funds; this includes the approval of all required documentation, i.e., CNA, IAP, Consultation Forms, etc.
- The CNA and IAP will need to be completed for FY21. However, there is no specific due date for these requirements. Please keep in mind, these items will need to be completed prior to being Director Approved.
- ED has provided a waiver for Section 1127(b) of Title I, Part A of the ESEA so that your State educational agency (SEA) may waive, more than once every three years, if necessary, the 15 percent carryover limitation in ESEA section 1127(a) for fiscal year (FY) 2019 Title I, Part A funds.
- ADE will be applying for this waiver within the next several days.
IES has released the following reminders and information to grantees:
- IES must review each grant’s progress before releasing funds for the next scheduled project budget period. Program officers will review your annual report (APR) to ensure you are making satisfactory progress towards completing planned project activities. This will continue to be true.
- If you anticipate needing to make COVID-19 related changes or adjustments to the originally funded scope and objectives of your project, you must receive approval from your program officer before making such changes. Any changes to the scope and objectives of a federally-funded project are significant, and maintaining contact with IES as you consider such changes will be critical.
- If you will be conducting any activities that require involvement from external partners – such as data collection, implementation, or evaluation activities to be performed at education sites – IES requires letters of agreement from any such education sites along with approval from your IRB before planned work may proceed. This includes any “planning” and “preparation” that may need to be conducted in preparation for activities that require involvement from external partners. Such letters must be received by IES before you may expend funds to support these planned activities. IES encourages you to reach out to education sites when they have the capacity to respond, and to work with your IRB office to address any changes you may need, or that the IRB may require. By contrast, activities that do not require on-going involvement from external partners – such as development of a curriculum or analyses of extant data – may proceed as planned.
- In general, if you anticipate any challenges or difficulties implementing your grant activities as proposed, please reach out to your IES project officer as soon as possible. IES will work with you to identify permissible strategies to address the difficulties you are facing. Their goal to is to partner with you by supporting you through the unique conditions and circumstances you may be facing as they emerge over time, while maintaining the scientific validity and integrity of your project.
RAs are also advised to review the IES FAQ page.