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Impact of the Coronavirus on Research Operations and Federal Grant Administration



 

 

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

%20%28003%29.pdf

 

2) COGR aggregation of key agency FAQs: https://www.cogr.edu/sites/default/files/COGR%20FAQs%20on%20COVID-

19%20Impact%20on%20Federal%20Awards%20V.2.1_0.pdf

 

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:

 

  1. 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.

     

    OSTP Memo: https://www.whitehouse.gov/wp-content/uploads/2020/03/COVID19-Open-Access- Letter-from-CSAs.Equivalents-Final.pdf

     

  2. 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:

  3. 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