Rensselaer Office of Research
Impact of the Coronavirus on Research Operations and Federal Grant Administration
April 8, 2020
The coronavirus and the subsequent public health response have impacted the operations of research universities and federal granting agencies. As a result, The White House Office of Management and Budget (OMB) has provided new guidance to federal agencies. Federal granting agencies are now providing information and guidance directly to grantees, awardees, contract recipients, and panelists regarding the impact of the coronavirus on research grant administration operations.
Agencies stress that this is a rapidly evolving situation and urge universities to continue to monitor agency websites for updated guidance and information as it becomes available. Most agencies direct people to their respective institutions for internal guidance on research operations as a first resource.
Because of the fluidity of this situation, much of the guidance originally issued by federal agencies was purposefully vague. However, agencies are now posting more specific guidance on their websites and through FAQs.
Council on Governmental Relations (COGR)
The Council on Governmental Relations (COGR) – of which Rensselaer is a member – has developed two great resources, 1) a detailed agency matrix to help faculty and university grant administrators determine which agencies have developed specific guidance in response to operations impacted by coronavirus, and 2) an aggregation of key agency FAQs:
1) COGR Agency Matrix: https://www.cogr.edu/sites/default/files/COVID19AgencyGuidanceMatrix%20v7%20April%201%202020
2) COGR aggregation of key agency FAQs: https://www.cogr.edu/sites/default/files/COGR%20FAQs%20on%20COVID-
Rensselaer is continuing to monitor websites and communications from individual agencies to determine any rules they are promulgating as a result of this OMB directive. Given the circumstances, PIs must fully document all grant activities – and activities of those working on grants – during this time.
Also, if you are contacted by your program manager or program office about grant operations during this time please contact the Office of Research and RAF prior to responding. To ensure a consistent message from the Institute, OVPR and RAF will work with you to develop your response to those agencies.
Below are links to information, guidance and FAQs from OMB, OSTP, individual federal funding agencies, and selected university advocacy organizations and associations:
Federal Government Information:
Office of Management and Budget (OMB):
The White House Office of Management and Budget (OMB) has issued two memos with directives to agency heads regarding COVID-19. Their first memo (M-20-11) dealt with impacts to research related to COVID-19 and the second memo (M-20-17) superseded that and provides guidance relating to grant operations impacted by COVID-19.
OMB Memo M-20-11: Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19): https://www.whitehouse.gov/wp- content/uploads/2020/03/M-20-11.pdf
OMB Memo 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: https://www.whitehouse.gov/wp-content/uploads/2020/03/M-20-17.pdf
OMB memo M-20-17 is important in that it offers direction to federal agencies regarding the allowability of salaries and other project activities, as excerpted below:
6. Allowability of salaries and other project activities. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405): Awarding agencies may allow recipients to continue to charge salaries and benefits to currently active Federal awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Awarding agencies may allow other costs to be charged to Federal awards necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. Awarding agencies may also evaluate the grantee's ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances based on subsequent progress reports and other communications with the grantee. Awarding agencies must require recipients to maintain appropriate records and cost documentation as required by 2 CFR § 200.302 -Financial management and 2 CFR § 200.333 - Retention requirement of records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services.
Office of Science and Technology Policy (OSTP):
The White House OSTP produced a memo urging scientists who publish to voluntarily agree to make their COVID-19 and coronavirus-related publications, and the available data supporting them, immediately accessible in PubMed Central and other appropriate public repositories, such as the World Health Organization’s COVID data base, to support the ongoing public health emergency response efforts.
Agency Specific Guidance:
National Institutes of Health:
NIH has established a website to communicate information to applicants and recipients during this time of disruption caused by the coronavirus: https://grants.nih.gov/grants/natural_disasters/corona- virus.htm
NIH Video Message: Dr. Mike Lauer, NIH Deputy Director for Extramural Research, posted this brief YouTube video to discuss donation of supplies, peer-review, emergency supplemental funds, no-cost
extensions, salary support, shifting money to out-of-scope Covid-related research, applications, reporting, re-budgeting, salaries & stipends, and travel (March 26, 2020): https://www.youtube.com/watch?v=V5-Ry-2uGxs
NIH info on salaries and stipends: One key question and answer of importance to all of us was posted on the NIH FAQs thread states that charging salaries to NIH grants when no work is being performed is allowable if your organization’s policy allows for the charging of salaries and benefits to currently active awards under unexpected or extraordinary circumstances. Below is an excerpt of the Q&A posted by NIH and here is a link to FAQs (See Section V. Costs): https://grants.nih.gov/faqs#/covid-19.htm
Q: Can a recipient continue to pay personnel costs under awards in the event of an emergency? A: Charging salaries to NIH grants when no work is being performed is allowable if your organization’s policy allows for the charging of salaries and benefits to currently active awards (under unexpected or extraordinary circumstances) from all funding sources, Federal and non- Federal. If you have such a policy, and anticipate a need to charge personnel costs, please notify the funding IC. NIH may request documentation to confirm the requirements of the institutional policy.
NIH has also posted information and FAQs on topics such as submission of progress reports, grant- related travel or conference attendance, attendance at events with large crowds, and application submission policies:
NIH FAQs: Guidance for Proposal Submission and Award Management Related to COVID-19: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-083.html
NIH LATE APPLICATION POLICY Due to Public Health Emergency for United States for 2019 Novel Coronavirus (COVID-19): https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-082.html
Late application guidance: When delays occur because the applicant or recipient organization is officially closed or unable to submit grant applications due to the effects of COVID-19, the NIH will consider accepting applications late, on a case-by-case basis, in accordance with the NIH Grants Policy Statement, Section 2.3.9, under the following circumstances:
Institutions must submit applications or reports as soon as possible after reopening or resuming operations so that grant applications can be submitted, not to exceed the number of days the institution was officially closed or unable to submit grant applications.
Institutions must submit a cover letter with the applications with enough detail about the delay so that NIH staff can make a determination whether circumstances justify accepting the application late.
Institutions need not request advance permission to submit late due to this declared emergency.
The NIH extramural blog provides additional information and some limited comments and answers, but also links to NIH resources on coronavirus impacted operations:
NIH Extramural Nexus Blog: https://nexus.od.nih.gov/all/2020/03/13/covid-19-resources-for-applicants- and-recipients-of-nih-funding/
NIH info on IACUC: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-088.html
NIH info on clinical trials and human subjects research: https://grants.nih.gov/grants/guide/notice- files/NOT-OD-20-087.html
Applicant/Recipient COVID-19 Update History: https://grants.nih.gov/policy/natural-disasters/corona- virus/history-update.htm
National Science Foundation:
On April 1, 2020, NSF posted a pdf document with FAQs and answers for proposers and awardees. The FAQs deal with NSF’s implementation of OMB’s Guidance.
NSF Implementation of OMB Memo M-20-17: https://www.nsf.gov/bfa/dias/policy/covid19/covid19_nsfombimplementation.pdf This memo details how NSF will handle several grant administration issues:
Allowability of salaries and other project activities
Allowability of Costs not Normally Chargeable to Awards
Prior approval requirement waivers
Exemption of certain procurement requirements
Extension of financial and other reporting
Extension of currently approved indirect cost rates
Close Outs and Single Audit Requirements
NSF Main Page for Coronavirus: https://www.nsf.gov/news/special_reports/coronavirus/
NSF Impact on existing deadlines: NSF Impact on existing deadlines: https://www.nsf.gov/bfa/dias/policy/covid19/covid19_deadlines.pdf
(As of April 7, 2020, NSF has extended their submission deadlines for a number of solicitations).
Frequently Asked Questions (FAQs) About the Coronavirus Disease 2019 (COVID-19) for National Science Foundation (NSF) Proposers and Awardees: https://www.nsf.gov/bfa/dias/policy/covid19/covid19faqs_proposerandawardee.pdf
Department of Energy:
The DOE has offered some direction and FAQs to proposers and awardees thus far. We are continuing to monitor DOE and selected DOE office websites for up to date information and directives.
Dr. Chris Fall, head of the office of science, posted this pdf memo with some information and Q&A regarding grant operations, applications, budget revisions, progress reports, and travel: https://www.energy.gov/sites/prod/files/2020/03/f72/doe-sc-accommodating-interruptions-to- applicants-awardees-due-to-covid-19.pdf
DOE Guidance for Financial Assistance Actions: https://www.energy.gov/management/downloads/pf- 2020-20-covid-19-guidance-financial-assistance-actions
ARPA-E issued guidance on April 3, 2020 (https://arpa-e.energy.gov/sites/default/files/COVID- 19%20Important%20Notice%20ARPA-E.pdf) addressing the COVID-19 impacts on research and in response to OMB guidance. This ARPA-E memo addresses several issues including – but not limited to – suggested project work-arounds, no cost extensions, and allowability of salaries and costs. ARPA-E has also created an email address for awardees to use specifically for COVID-19 related budget and administration issues. The email is embedded in the memo linked above.
DOE / Office of Nuclear Energy's (NE) Nuclear Energy University Program (NEUP): DOE-NE is issuing guidance in consideration of DOE Policy Flash (PF) 2020-20, which is the Department of Energy’s (DOE) implementation of OMB Memorandum M-20-17 entitled, “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations.” The PF provides information to financial assistance award recipients clarifying several procurement related topics, including no cost extensions, allowability of salaries and other project activities, allowability of cost not normally chargeable to awards, and the extension of financial, performance, and other reporting requirements. The full guidance document is available at: https://neup.inl.gov/Lists/Headlines/AnnouncementDispForm.aspx?ID=209
Department of Defense:
The DOD has offered some direction and FAQs to proposers and awardees. We are continuing to monitor DOD and selected DOD research office websites for up to date information and directives.
DOD Office of Basic Science posted limited COVID-19 FAQs on its website: https://basicresearch.defense.gov/COVID-19/Frequently-Asked-Questions/
A key question and answer from DOD Basic Science is excerpted here:
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 Memorandum 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.
DOD components may allow other costs to be charged to federal awards necessary to continue work on a project even if in a period where primary research activities are limited or curtailed. To the maximum extent practicable, recipients will be expected to invoke or institute any and all reasonable mitigation actions and practices to lessen the cost to the government during the
crisis period. Such actions may be part of an existing program created by the recipient or may be created to respond to this crisis. Appropriate records and cost documentation must continue to be updated and maintained as required by 2 CFR 200.302 - Financial management and 2 CFR
200.333 - Retention requirement of records.
DARPA created a web resource and FAQs on March 19th related to grant operations disrupted by coronavirus: https://www.darpa.mil/news-events/2020-03-19
DARPA Terms and Conditions: https://www.darpa.mil/attachments/DoDTermsandConditionsforCOVID19Waivers.pdf
Two key questions of concern posted in the DARPA FAQs are as follows:
Q: My project is delayed or disrupted due to COVID-19. I need an extension of the period of performance or some other modification. What should I do?
A: First, document the delay, the impact to your project, what caused it, what you did or have done to mitigate the delay, and any other relevant facts and details. As soon as possible, contact your Contracting Officer, Grants Officer, or Agreements Officer in writing. Explain all facts and details of the situation, provide documentation, and be sure to note that COVID-19 is one of the reasons for your modification request.
Q: I have a question about incurring additional costs related to COVID-19. What should I do? A: Always carefully document any incurred costs and any relevant facts and details about what caused them. As soon as possible, email your Contracting/Grants/Agreements officer. In your email, relay all the pertinent facts so the Government can answer your inquiry as soon as possible.
In keeping with other agencies, DARPA is urging PIs to contact their respective contracting officers and to fully document activities, costs and delays!
USAMRAA: FAQs from United States Army Medical Research Acquisition Activity: https://www.usamraa.army.mil/Shared%20Documents/USAMRAA%20Supplemental%20Guidance%20o n%20COVID-19_03.25.20%20for%20pdf.pdf
DOD Congressionally Directed Medical Research Program (CDMRP): https://cdmrp.army.mil/about/covid-19/default
NAVY - Assistant Secretary of the Navy for Research, Development and Acquisition: https://www.cogr.edu/sites/default/files/ASN-RDA%20RD%20Engagement_24Mar20.pdf
Office of Naval Research (ONR) Coronavirus Assistance and Acquisition-Related Information and Resources: https://www.onr.navy.mil/coronavirus
National Aeronautics and Space Administration:
Statement from NASA Administrator on coronavirus: https://www.nasa.gov/press-release/nasa- administrator-march-17-statement-on-agency-response-to-coronavirus
NASA Info for Grantees: https://www.nssc.nasa.gov/grants
NASA Info on OMB Guidance M-20-17: https://searchpub.nssc.nasa.gov/servlet/sm.web.Fetch/NASA_s_Implementation_of_M-20-17_COVID- 19.pdf?rhid=1000&did=6440077&type=released
NASA Grants and Research During COVID-19: https://searchpub.nssc.nasa.gov/servlet/sm.web.Fetch/FAQ-NASA_COVID-19_M-20- 17 Final.pdf?rhid=1000&did=6440084&type=released
Department of Transportation:
U.S. Department of Transportation Announces Deadline Extension for Federal Transit Administration Competitive Grant Programs: https://www.transit.dot.gov/us-department-transportation-announces- deadline-extension-federal-transit-administration-competitive
USDA - National Institute of Food and Agriculture:
Information and FAQs from USDA: https://www.usda.gov/coronavirus
Department of Justice – Office of Justice Programs (OJP):
OJP Administrative Guidance: https://www.cogr.edu/sites/default/files/OJP_Guidance_on_Short_Term_Administrative_Relief_March
University Organizations & Associations – Information and Resources:
Council of Governmental Relations (COGR):
COGR is an association of research universities and affiliated medical centers and independent research institutes. COGR’s website is a great, one-stop resource for a long list of links and resources for information on federal agency guidance, university policies, and operational impacts of the coronavirus crisis: https://www.cogr.edu/institutional-and-agency-responses-covid-19-and-additional-resources
National Association of Independent Colleges and Universities (NAICU):
The NAICU website is primarily focused on impacts to research operations at universities. Instead, it has a coronavirus resource to assist member institutions (RPI is a member) with planning for and managing a potential outbreak of Coronavirus Disease (COVID-19) on campus. The site also tracks news related to the spread of the disease within the Higher Ed community, and posts other national and regional health resources: http://www.naicu.edu/research-resources/coronavirus-disease-covid-19-resources
National Association of College and University Business Officers (NACUBO):
NACUBO website lists limited resources for federal guidance for colleges and universities: https://www.nacubo.org/Topics/Risk-Management-and-Campus-Security/Emergency- Preparedness/Covid-19-at-your-campus/?utm_source=hp&utm_medium=nacubo&utm_campaign=bom
Four major university associations (AAU, COGR, APLU, AAMC) sent a letter to OMB urging them to expand on their directive in OMB memo M-20-11 and give more guidance and flexibility to universities given the fluid nature of the coronavirus impact. After this letter, OMB issued expanded guidance in memo M-20-17. (See links to memos in OMB section above).
Letter from university organizations to OMB urging: Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19): https://www.aau.edu/sites/default/files/AAU-Files/Key-Issues/JointAssociationLettertoOMBOnM-20- 11Expansion.pdf