UPDATED: Reducing Impact of COVID-19 on ASU Research Activities

Post Last Updated 6/29/2020 – 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. 

Answer(s) not found in this FAQ, then submit a question via this  link

JUST POSTED! (Any updates from the last two business days)

Families First Coronavirus Response Act (FFCRA) Earning Codes (Section added 06/29/2020 at 7:00 PM)

New earnings codes have been added to PeopleSoft to capture leave time specifically related to COVID-19 circumstances, including employee COVID illness, employee family member COVID illness and COVID-related childcare issues (https://www.asu.edu/hr/wellness/FFCRA-reporting-process.pdf). These new earnings codes are allowable on sponsored accounts but should not be confused with charging employee ‘idle time’ to sponsored accounts using existing earnings codes under the OMB administrative flexibilities in effect through September 30, 2020 (https://www.whitehouse.gov/wp-content/uploads/2020/06/M-20-26.pdf).

Expired Guidance from the Office of Management & Budget (Section Added 06/29/2020 at 7:00PM)

The administrative flexibilities outlined in Memorandum M-20-17 issued by the Office of Management & Budget expired on 06/16/2020. A new section has been created under “Additional Resources” as a repository of flexibilities that were issued by OMB due to COVID-19 but are no longer in effect. These expired flexibilities are included for reference only. RAs are advised to apply OMB administrative flexibilities only during the effective period of the memorandum.

Current Guidance from the Office of Management & Budget (Section Updated 06/29/2020 at 7:00PM)

This section has been updated to include recently issued guidance from the Office of Management & Budget.

On June 18,2020, OMB issued memorandum M-20-26. M-20-26 only extends two administrative flexibilities originally provided in M-20-17. These are:

  • Item 1 –  Allowability of salaries and other project activities (item 6 in M-20-17), Expires 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:

“Due to the limited funding resources under each federal award to achieve its specific public program goals, awarding agencies must inform recipients to exhaust other available funding sources to sustain its workforce and implement necessary steps to save overall operational costs (such as rent renegotiations) during this pandemic period in order to preserve Federal funds for the ramp-up effort. Recipients should retain documentation of their efforts to exhaust other funding sources and reduce overall operational costs.”

  • 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.

Personal Protective Equipment (Section Updated 06/29/2020 at 7:00PM)

The section “Donations of PPE Purchased with Sponsored Funds” has been updated. OMB guidance issued under M-20-20, which allowed the repurposing of PPE purchased with Federal sponsored funds, expired on 06/16/2020.

Canceled Travel on Sponsored Projects (Section added on 06/30/2020 at 10:00AM)

OMB guidance on administrative flexibilities issued in March 2020, allowed the charging of costs associated with canceled travel due COVID-19 to Federal grants. RAs are advised that, as OMB Memorandum M-20-17 expired on 06/16/2020, costs for canceled travel will no longer be allowed on Federal grants (including NIH grants). Costs associated with canceled traveled incurred on or after 06/17/2020 will need to be charged to a non-sponsored account or will require prior sponsor approval. For canceled travel incurred on or before 6/16/2020, units should continue to follow the “Best Practices for Canceled Travel Documentation.”

National Institutes of Health (Section updated on 06/30/2020 at 10:00AM)

On June 25, 2020 NIH released guidance on the Implementation of OMB Memorandum 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” dated June 18, 2020. RAs are encouraged to review NIH’s guidance, available here. Of particular interest to the RA community:

  • 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.  

Any questions regarding the NIH implementation of M-20-26 should be directed to the NIH Office of Policy for Extramural Research Administration at grantspolicy@nih.gov.

FREQUENTLY ASKED QUESTIONS & PAST UPDATES

(Section added 06/18/2020 at 9:00 AM)

Investigators looking to ramp up on-campus research activities, must create and submit a lab, human subjects or field safety plan using the Research Intensification online platform. The platform includes resources and guidance (including Human Subjects), as well as individual portals for each of the three research safety areas. Investigators are encouraged to review the Research Intensification page for more information.
(Section Updated 03/31/2020 at 3:00PM) I have received notification from a sponsor/agency where they have indicated one of the following:

  • 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
What steps should I take?

Send the email to your Research Administrator and PNT (ProposalandNegotiation@asu.edu) Upon receipt of the email, your award terms and conditions will be reviewed by an ASU PNT Contracts Officer.   The ASU PNT Contracts Officer will connect with you and your Research Administrator on necessary steps to be taken and will also facilitate changes to any post-award sponsored functions.
Salary Support  (Section Added 3/27/2020 at 3:00PM)

Can I continue charging of salaries and fringe to grants, regardless of work schedules?

Yes, continue charging salaries and fringe to your sponsored project.  Some agencies such as NSF, NIH and DOD have already issued statements in line with this guidance and it is anticipated other sponsors will release similar guidance.  In addition, it is important to consider that many sponsors do not expect to increase funding of projects due to COVID-19 and to maintain documentation of effort exerted in support of the grant remotely vs. effort taken without the ability to perform work on the grant.

Best practices for summer renewals  (Section added 04/16/2020 at 10:00am)

Good documentation is one of the keys to effectively managing cost allowability issues as COVID-19 flexibilities develop. Every unit’s situation will be unique. Below is an example that may help you in developing guidance for your unit.

PERSONNEL COSTS: For continued payment of personnel who are currently unable to work remotely on the project from which they were being paid –

  • 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,
cid:image001.png@01D61234.D9DE4430
This announcement is available at https://eoss.asu.edu/health/announcements/coronavirus#covid-archive
  • 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.
After-the Fact Review Reports (Section Added May 4, 2020 at 2:00PM)

ASU’s institutional position is to continuously pay grant-funded employees without interruption during the COVID-19 pandemic. To reflect ASU’s position on personnel salary, the PI acknowledgement statement for After-the-Fact Review Reports has been updated as follows:

You are acknowledging that all personnel expenses are consistent with university policy and are accurate, allowable, allocable, and reasonable for both the work performed and the COVID-19 flexibilities allowed.

International Students & Postdocs on Sponsored Projects (Section added June 1, 2020 at 2:00PM)

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
Update to University Travel (Section updated 06/15/2020 at 3:00pm)

University-sponsored international travel is prohibited at this time. University-sponsored domestic travel must receive approval from a dean or vice president, as well as an executive vice president. This policy, available here, also applied to grant-funded travel for ASU employees.

Canceled Travel on Sponsored Projects (Section added on 06/30/2020 at 10:00AM)

OMB guidance on administrative flexibilities issued in March 2020, allowed the charging of costs associated with canceled travel due COVID-19 to Federal grants. RAs are advised that, as OMB Memorandum M-20-17 expired on 06/16/2020, costs for canceled travel will no longer be allowed on Federal grants (including NIH grants). Costs associated with canceled traveled incurred on or after 06/17/2020 will need to be charged to a non-sponsored account or will require prior sponsor approval. For canceled travel incurred on or before 6/16/2020, units should continue to follow the "Best Practices for Canceled Travel Documentation."

Best Practices for Canceled Travel Documentation (Section updated 06/30/2020 at 10:00AM)

OMB Memorandum M-20-17 provided flexibilities to direct charge costs associated with canceled travel due COVID-19 for expenses incurred on or before 06/16/2020. Good documentation is one of the keys to effectively managing cost allowability issues as COVID-19 flexibilities develop. Every unit’s situation will be unique. Below is an example that may help you in developing guidance for your unit. To document canceled travel and handle resulting travel credits –

  • 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,

ASU now prohibiting university- and grant-funded domestic travel While the Centers for Disease Control and Prevention does not generally issue advisories or restrictions for travel within the U.S., cases of COVID-19 have been reported in many states and some areas are experiencing community spread of the disease. The CDC has noted that crowded travel settings, like airports, may increase your risk of exposure to COVID-19, if there are other travelers with COVID-19. With this in mind, the university is now prohibiting all university- and grant-funded travel within the U.S. and internationally.  

This announcement is available at https://eoss.asu.edu/health/announcements/coronavirus#covid-archive
  • 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.

As a reminder, effective 3/25/2020, projects involving face-to-face interactions with human subjects must be suspended.

If you are looking to ramp-up human subjects research, review the guidelines and policies in the Research Intensification PlanAs of 6/18, the third portal, Human Subjects, was released along with Human subjects guidance

Note:  The On-Campus Research Oversight Committee will provide you with notification if your submitted plan can proceed.  This step must be completed first and then the PIs/researcher will work with ORIA on needed approvals by the appropriate institutional committees (IRB, IACUC, IBC).   

If you have a question about your compliance approval (e.g. IRB) or a compliance (e.g. IRB) approval or modification to an existing approval is needed, please contact research.integrity@asu.edu

The ORIA IRB staff continues to be available to support your human subjects research needs during these very challenging times.   Please don’t hesitate to contact us directly at research.integrity@asu.edu.

I am a PI/researcher who has non ASU parties doing (or resuming) in-person contact work (for research) and being paid to do that under an ASU subaward (e.g. University) or ASU PO (e.g. lab/clinic).   If the non ASU party has its own IRB for its work and is required to follow their own policies/procedures for the human subjects research, what policies do they follow? 

They would follow their own educational institutional policies unless ASU have notified the non ASU party to suspend and/or stop work.  
For projects involving the use of laboratory animals, planned activities are continuing and access to research spaces are accessible to ASU personnel.  The Department of Animal Care and Technologies (DACT), the Office for Research Integrity and Assurance (ORIA) and ASU IACUC are fully operational.  If the need arises, this website will be updated.  
My lab has PPE stock beyond what is needed for immediate activities. Can I donate PPE to labs needing equipment?

Donations of PPE Purchased with Non-Sponsored Funds

If you have PPE (masks, gloves, face shields, glasses/goggles) not purchased with grants funds and are in a position to donate to other ASU labs. Document the PPE that is being donated, including costs and to which ASU lab.  Costs for future reimbursement/replacement of PPE will be managed at a later date – either through a re-allocation of costs or replacement from other funds.

Donations of PPE Purchased with Sponsored Funds

RAs are encouraged to review OMB guidance M-20-20: Repurposing Existing Federal Financial Assistance Programs and Awards to Support the Emergency Response to the Novel Coronavirus (COVID-19) (4/9/20). M-20-20 authorizes agencies to allow donation of PPE and other supplies and re- assignment of personnel paid for with grant funding to emergency response efforts. Where applicable, contact the Sponsor Grants Officer for approval. When donating PPE, units must document the PPE that is being donated, including costs and the associated award. RAs should note that M-20-20 expired on 06/16/2020 and apply the guidance accordingly.
In light of the current situation with COVID-19, some Sponsors are requesting the PI and/or institution to report on potential risks facing the project as well as any mitigation measures.  If you are contacted and unsure on how to respond, contact Heather Clark, Executive Director – Research Operations; heather.christina.clark@asu.edu for assistance.

ASU RESOURCES

Principal Investigators can find updated information here: https://research.asu.edu/covid-19. Please note that these updates are high-level. More detailed information impacts on operations will be disseminated through the Research Operations News.
Official ASU COVID-19 updates impacting students, faculty, and staff: https://eoss.asu.edu/health/announcements/coronavirus
Looking for a COVID-19 funding opportunity?

Visit COVID-19 Related Funding Opportunities and Researcher Resources. This page will provide high-level opportunities that are fit for university-wide dissemination and action. For COVID-19 specific funding opportunities, please utilize the Pivot Curated search and the Coronavirus Funding Monitor portal.

National Institutes of Health (NIH) COVID-19 Funding and Funding Opportunities (Section updated 04/16/2020 at 10:00am)

NIH has received emergency funding for COVID-19-related activities in two supplemental bills (available from the NIH Office of Budget website).

Want to know more click here.

Space Telescope (STScI)  - COVID-19 Impact on the James Webb Space Telescope (JWST) Cycle 1 GO Proposal Deadline (Section added 04/16/2020 at 10:00am)

JWST deadline has been further delayed and a revised deadline will not be announced at this time.  An update will be provide around June 1st, 2020.  The JWST Call remains open and all proposal preparation tools and documentation continue to be available.  Please contact the jwst helpdesk if you have any questions.

Bill and Melinda Gates Foundation (Section added 04/16/2020 at 10:00am)

Grant Opportunities from the Gates Foundation

Grant applications are still being accepted by the Bill & Melinda Gates Foundation for the following Grand Challenges and Grand Challenges Explorations initiatives. The Grand Challenges family of initiatives fosters innovation to solve key global health and development problems. The application deadline is April 22, 2020. COVID-19 Opportunities

The Bill & Melinda Gates Foundation has committed funding to the global response to COVID-19. To learn more about the foundation's broader work and how the COVID-19 pandemic is being addressed across the foundation, please visit the foundation's website and also sign-up for The Optimist newsletter.

ADDITIONAL RESOURCES

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)

M-20-26 (Issued 06/18/2020)
Contracts M-20-18 (Issued 03/20/2020)

*Guidance for Grant & Cooperative agreements is applicable only to awards that were active at the time the guidance was issued. It is not applicable to expired awards or awards made after the issue date.

Agencies should provide specific agency guidance, consistent with the OMB guidance. COGR has an inventory of all the available Agency guidance that the RA community is encouraged to review.

GRANTS & COOPERATIVE AGREEMENTS*

On March 9, 2020 OMB issued M-20-11 “to provide agencies with additional flexibilities for grants assisting the response to COVID-19. The scope of the M-20-11 was narrowly crafted to provide flexibility to grant recipients performing essential research and services necessary to carry out the emergency response related to COVID-19”.

On June 18, 2020 OMB issued M-20-26, which only extends only two of the multiple flexibilities originally provided under M-20-17.

OMB pointed out key differences between the flexibilities permitted by M-20-11 and those allowed by M-20-26 as bulleted below:

M-20-26

OMB memorandum M-20-26 only extends two administrative flexibilities originally provided in M-20-17. These are:

  • Item 1 -  Allowability of salaries and other project activities (item 6 in M-20-17), Expires 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:

“Due to the limited funding resources under each federal award to achieve its specific public program goals, awarding agencies must inform recipients to exhaust other available funding sources to sustain its workforce and implement necessary steps to save overall operational costs (such as rent renegotiations) during this pandemic period in order to preserve Federal funds for the ramp-up effort. Recipients should retain documentation of their efforts to exhaust other funding sources and reduce overall operational costs.”

  • 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-20-11

  • 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.”

CONTRACTS

OMB guidance on contracts is included in M-20-18. RAs are reminded that:

  • 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”.
The Office of Management & Budget issued three memoranda outlining administrative flexibilities meant to provide short-term administrative, financial and audit requirements under the 2 CFR 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, without compromising Federal financial assistance accountability requirements. The flexibilities below have expired and are included here for reference only. When applying OMB flexibilities to grant expenditures and award management, make sure that these are applied during the allotted period only.

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 - EXPIRED JUNE 16, 2020

  • 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

As RAs review currently posted OMB guidance, it is important to keep in mind that while NIH’s notice appears to allow an extended pre-award cost period back to 01/20/2020 for grantees affected by COVID-19, OMB’s guidance only allows extension of the pre-award cost period back to 01/20/2020 for grantees whose funding was awarded specifically to address the COVID-19 pandemic.
The Council on Governmental Relations (COGR) is collecting institutional and agency responses COGR Federal Agency Guidance. Additional COGR resources are included below: Council on Governmental Relations (COGR) Updates (Section updated 04/16/2020 at 10:00am)
  • 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.

SPONSOR GUIDANCE

The National Science Foundation has issued Important Notice No 146 to the Community Regarding COVID-19. NSF has implemented flexibilities authorized by OMB from specific administrative, financial management and audit requirements and has also issued revised guidance on NSF’s implementation of the Office of Management and Budget (OMB) Memorandum (M-20-17). Revisions include:
  • 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.
Any questions about the policies described in the NSF Guidance should be directed to policy@nsf.gov.

Questions specific to a particular award should be directed to the cognizant NSF Program Officer. NSF is working to update existing FAQs and other resources to reflect NSF’s new guidance and will keep you informed on our website at: nsf.gov/coronavirus.

The RA Community is also encouraged to review the following resources and notices: Frequently Asked Questions (FAQs) About the Coronavirus Disease 2019 (COVID-19) for NSF Panelists – March 17, 2020

National Science Foundation (NSF) Implementation of OMB Memorandum M-20-20 (Section updated 04/16/2020 at 10:00am)

A MESSAGE FROM JEAN FELDMAN, HEAD POLICY OFFICE, NATIONAL SCIENCE FOUNDATION
The Foundation has issued guidance on NSF’s implementation of the Office of Management and Budget (OMB) Memorandum (M-20-20), entitled, Repurposing Existing Federal Financial Assistance Programs and Awards to Support the Emergency Response to the Novel Coronavirus (COVID-19).  NSF remains committed to working with the Administration, other federal agencies, and the research community to effectively respond to the COVID-19 national emergency.  This guidance is to implement the flexibility class exception authorized by OMB Memorandum M-20-20 that allows Federal awarding agencies to repurpose their Federal assistance awards (in whole or part) to support the COVID-19 response, as consistent with applicable laws. This will certainly help address questions that recipients may have regarding the donation of items/resources from NSF awards.

Any questions about the policies described in the NSF Guidance should be directed to policy@nsf.gov.  Questions specific to a particular award should be directed to the cognizant NSF Program Officer.  NSF is working to update existing FAQs and other resources to reflect NSF’s new guidance and will keep you informed on our website at: nsf.gov/coronavirus.
NIH Implementation of OMB M-20-26 (Section updated on 06/30/2020 at 10:00AM)

On June 25, 2020 NIH released guidance on the Implementation of OMB Memorandum 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” dated June 18, 2020. RAs are encouraged to review NIH’s guidance, available here. Of particular interest to the RA community:

  • 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.
 

Any questions regarding the NIH implementation of M-20-26 should be directed to the NIH Office of Policy for Extramural Research Administration at grantspolicy@nih.gov.

NIH NOT-OD-20-086 (Section Updated 06/30/2020 at 12:00PM)

RAs are advised that NIH rescinded some of the flexibilities outlined in NOT-OD-086. Effective 06/17/2020, NIH will not allow direct charge of canceled travel and conference registration fees due to COVID-19. The information listed under this section is presented for reference only, and applies to expenditures with a date of 06/16/2020 or earlier. Flexibilities associated with Salaries have been extended and will continue through 9/30/2020 (See NIH Implementation of OMB M-20-26 above.

Due to the HHS declared public health emergency for COVID-19, NIH has issued a notice (NOT-OD-20-086) outlining short-term administrative flexibilities to assist grantees with managing administrative, financial management and audit requirements without compromising their accountability requirements.

Units are advised to download and review the NIH COVID-19 Flexibilities Guide available here. A selection of these flexibilities is included below:

TOPIC FLEXIBILITY ALLOWED SYNOPSIS ACTION***
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.

Office of Energy Efficiency and Renewable Energy (EERE) (Section added 3/27/2020 3:00 PM)

Recommends close communication with your DOE Contracting Officer (CO) and project if you believe that your coronavirus response strategy might disrupt project timelines or deliverables.
NIFA Deadline Extensions Due to COVID-19 Additional NIFA information (Section added 3/27/2020 3:00 pm) Please know that NIFA is committed to adhering to OMB’s memorandum while simultaneously working with recipient organizations to provide the right solutions as deemed appropriate and to the extent permitted by law. Questions regarding the applicability of the memorandum’s administrative relief provisions should be directed to NIFA’s Awards Management Division at awards@usda.gov. For more information, see (OMB’s M-20-17).
U.S Department of Interior has delayed the implementation of GrantSolutions. May 18, 2020 is now the anticipated go-live date for transition to the system.  Award processing will be discontinued for approximately 2 weeks prior to the May 18, 2020 go-live date.

Upcoming key dates:

  • 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
References:
ADE's response to COVID-19, please visit ADE's Office of Communications page.

1. May 1, 2020 due date:
  • 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.
2. 15% Carryover Limit Title I:
  • 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.
3. CSI/TSI Carryover: Even though CSI and TSI grants are competitive in nature, in consideration of our current situation, there will be increased flexibility including carryover of funds.  Expect specific guidance within the next week.

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.