Research Impact of Coronavirus Disease 2019 (COVID-19)

The potential impact of the respiratory illness COVID-19 continues to evolve. UCSF Office of Sponsored Research (OSR) and Contracts and Grants Accounting (CGA) are actively monitoring the impacts to research activities and funding.  

The Office of Sponsored Research (OSR) is working remotely and remains open for business during the present public health emergency.  Currently federal agencies are very flexible (see Sponsor Guidance below) about deadlines under difficult circumstances beyond our control. However, if agencies are officially closed, proposals will most likely remain in a queue, pending resumption of agency operations – as has been the case during federal budget-related shutdowns. The OSR, Office of Clinical Trial Activation (OCTA), and Contracts and Grants Accounting (CGA) are working to ensure continuity of services for researchers, as well as prioritizing COVID-19 research and clinical trials.

 If you have unanswered questions or needs related to COVID-19, please send them to this centrally-monitored email so that the issues are assigned for appropriate follow up: [email protected] 

This page will be regularly updated to provide information regarding the following:  

 


 

Sponsor Specific Guidance

This section is being updated daily and provides a summary of guidance collected from various notices and FAQs from the Sponsors noted. Below are the topics covered. Please work with your OSR Staff if you need to notify a Grants Office or Program Officer regarding any of these topics. 

Federal Sponsors (NIH, NSF, DOD, DOD-USAMRAA, DAF-AFOSR, CDC, HHS-OASH, ACF, AHRQ, SAMHSA):

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Non-Federal Sponsors

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Late Submission Policy

exception to the policy for post-submission materials (NOT-OD-19-083) for applications submitted for the January 2021 council (beginning with applications submitted for the May 25, 2020 due date for Fall 2020 review meetings). NIH, AHRQ, and NIOSH will accept a one-page update with preliminary data as post-submission materials for applications submitted under all activity codes, ONLY if the Funding Opportunity Announcement (FOA) used for submission allowed preliminary data in the application. One page of preliminary data will be accepted for single component applications or for each component of a multi-component application.

NIH

NIH has charted the Application Review Process to be followed during the COVID-19 pandemic. The chart covers flexibilities provided for the current and next round of peer review.

NIH, AHRQ, AND NIOSH provide an exception to the policy for post-submission materials (NOT-OD-19-083) for applications submitted for the January 2021 council, beginning with applications submitted for the May 25, 2020 due date for Fall 2020 review meetings. If the FOA for the application allowed preliminary data, a one-page update with preliminary data will be accepted as post-submission materials for single component applications or one page for each component for multi-component applications. The deadline for submitting all post-submission materials, including preliminary data, will be 30 days before the study section meeting. 

  • Post-submission materials will not be accepted for emergency competitive revisions and urgent competitive revisions because they undergo expedited review.


Institutional Training Grant applications submitted to the Parent Funding Opportunity Announcements PA-20-142 and PA-20-162, with a due date of May 25, 2020, will be accepted through June 30, 2020:

  • Applicants need not request advance permission to submit late and a cover letter providing justification is not required.
  • It is anticipated (but not guaranteed) that late applications submitted by June 30, 2020 will be reviewed in the council round to which they were submitted (e.g. January 2021).
  • Some Institutes/Centers (ICs) may be able to accept applications beyond the June 30, 2020 deadline; however, applicants must contact the IC first in order to confirm that a later date is possible. 
  • IC-specific late application policy update Notices are listed below under NIH Notices.

Note: ICs are issuing Change Notices for specific FOAs announcing Changes to Key Dates, please check new Change Notices for extensions and date revisions in the NIH weekly Guide or by checking the browser version of the FOA for Related Notices.

  • Late submissions should include a cover letter with enough detail describing the reason(s) for the delay so that NIH staff can make a determination that circumstance(s) justify acceptance of a late application.  
  • NIH will extend the expiration date of FOAs that expire prior to May 1 for 90 days to accommodatesubmission of late applications. Grants.gov will be adjusted to allow NIH to receive these applications. 
  • If an application has already been submitted exception to the policy for post-submission materials (NOT-OD-19-083) for applications submitted for the January 2021 council (beginning with applications submitted for the May 25, 2020 due date for Fall 2020 review meetings). NIH, AHRQ, and NIOSH will accept a one-page update with preliminary data as post-submission materials for applications submitted under all activity codes, ONLY if the Funding Opportunity Announcement (FOA) used for submission allowed preliminary data in the application. One page of preliminary data will be accepted for single component applications or for each component of a multi-component application. Principal Investigators should work with their RSC as concurrence of the Authorized Organizational Representative (AOR) is required.
  • NIH assures applicant community that peer review will continue to take place. NIH will be flexible about accommodating virtual participation for aspects of peer review that would otherwise require in-person meetings.

 

SOURCE: NIH GPS 2.3.9, NIH FAQs, NOT-OD-20-082, NIH COVID-19 Q&A recording, NOT-OD-20-091, NOT-OD-20-105, NOT-OD-20-123

NSF

NSF has extended deadline dates for specific funding opportunities listed on the Foundation’s COVID-19 webpage. Deadline for funding opportunities that do not appear on the list remain unchanged. If unable to meet stated NSF deadlines please contact the cognizant NSF Program officer to discuss the issue ideally BEFORE the deadline. NSF will consider extension on a case-by-case basis.  Principal Investigators should work with their RSC to follow guidance given by NSF Program Officer for submitting late application. NSF website has a list of impact on existing deadline dates.   

SOURCE: NSF COVID-19 FAQs,PAPPG Chapter 1.F , NSF Implementation of OMB M-20-17

DOD

DOD recommends that program offices provide flexibility with upcoming proposal deadlines to the extent allowable by funding authorities and by the time needed for merit review of submitted proposals. Please contact the program officer and grants manager for the funding opportunity in question to request an application deadline extension. Proposers are encouraged to monitor grants.gov to see if an extension has been posted.

SOURCE: FAQs for DOD Research Proposers and Awardees Impacted by COVID-19

DOD-USAMRAA

There are currently no plans to modify existing deadline dates. Applicants should monitor Grants.gov for any potential changes to an application deadline.

The unique and evolving circumstances related to COVID-19 create multiple challenges for conducting reviews that limit the extent to which timelines for funding can be delayed. Current funding opportunity announcement deadlines allow as much time as possible for application submissions, and further modification of application deadlines is not anticipated.

SOURCE: USAMRAA’s COVID-19, USAMRAA Supplemental Guidance April 30, 2020

CDC

 

CDC will consider extending the application due date beyond the date specified in the Notice of Funding Opportunity (NOFO) on a case-by case basis.  Principal Investigators should work with their RSC to submit your request to extend the NOFO deadline to the assigned grants management specialist/program official noted in the Notice of Funding Opportunity under Agency Contacts prior to the NOFO closing date. The request should include enough detail about the delay so that CDC can determine whether circumstances justify extending the NOFO application submission deadline. 

SOURCE: Flexibilities Available to Applicants and Recipients Affected by COVID-19 and FAQs

HHS-OASH*

No guidance at this time

ACF

ACFwill post specific guidance on its websites and/or provide a point of contact for an Agency program official.

SOURCE: Administration for Children & Family IM-ACF-OA-2020-01

AHRQ

AHRQ will accommodate late proposal through May 1, 2020; however, cannot guarantee that all late applications submitted by this date will be reviewed in the council round to which they are submitted. Applicants should assume that late applications submitted after May 1 may experience delays in peer review.

SOURCE:  NOT-HS-20-010

SAMHSA

No guidance at this time.

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Pre-Award Costs

NIH

Recipients affected by COVID-19 maypre-award spend from January 20, 2020 through April 30, 2020 as outlined in the declaration of the public health emergency.

SOURCE: NIH FAQs, NOT-OD-20-086

NSF

Pre-award costs may be incurred (at your own risk) up to 90 calendar days prior to the start date of the period of performance, as long as costs are made and document in accordance with the recipients’ procedures and is necessary for the effective and economical conduct of the project. Prior Approval required for pre-award costs for periods exceeding 90 days.

SOURCE: NSF PAPPG Chapter X.A.2.b

DOD

Pre-award costs may be incurred (at your own risk) up to 90 calendar days prior to the start date of the period of performance, as long as costs are allowable charges to the project or program.

SOURCE: DOD Research & Development (R&D) General Terms and Conditions, Part 2, Article V., Section C, Financial and Program Management

DOD-USAMRAA

Pre-award costs may be incurred (at your own risk) up to 90 calendar days prior to the start date of the period of performance, as long as costs are allowable charges to the project or program. Defers to ( DoD Research & Development (R&D) General Terms and Conditions, Part 2, Article V., Section C, Financial and Program Management.

Recipients should consult the Grant Officer regarding other potential prior approval waivers based on project-specific circumstances.

All costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award, except where specified in OMB Memorandum M-20-17.

USAMRAA will extend flexibilities to awards that support efforts related to COVID-19 on a case-by-case basis. Please work with your OSR Staff to contact the Grants Management Specialist or Grants Officer’s Representative listed in the award document for information concerning individual awards.

SOURCE: USAMRAA Supplemental Guidance March 25, 2020, FAQs from COGR March 19, 2020

CDC

No guidance at this time

HHS-OASH*

No guidance at this time

ACF

No guidance at this time

AHRQ

AHRQ is allowing pre-award spending from January 20, 2020 through the COVID-19 public health emergency period and prior to the date of a federal award for recipients that are impacted by COVID-19 (e.g. loss of operations). All costs charged must be consistent with Federal cost policies and terms of award.

SOURCE: NOT-HS-20-010

SAMHSA

No guidance at this time.

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 Carry Forward of an Unobligated Balance

NIH

Under the Standard Terms of award, recipients of SNAP awards can carryover an unobligated balance to a subsequent budget period. Recipients of non-SNAP awards have the discretion to carry forward unobligated balances on their active award for immediate efforts to support activities related to or affected by COVID-19 as long as the charges are allowable costs and are within the scope of the original award.

SOURCE: NIH GPS 8.1.1.2, NIH FAQs, NOT-OD-20-086, NOT-OD-20-087

NSF

No guidance at this time

DOD

Carry forward of an unobligated balance to a subsequent period of performance under the award is allowed.

 

SOURCE: DOD Research & Development (R&D) General Terms and Conditions, Part 2, Article V., Section C, Financial and Program Management

DOD-USAMRAA

Allows carry forward of an unobligated balance to a subsequent period of performance under the award. Defers to the DoD Research & Development (R&D) General Terms and Conditions, Part 2, Article V., Section C, Financial and Program Management.

Recipients should consult the Grant Officer regarding other potential prior approval waivers based on project-specific circumstances.

All costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award, except where specified in OMB Memorandum M-20-17.

USAMRAA will extend flexibilities to awards that support efforts related to COVID-19 on a case-by-case basis. Please work with your OSR Staff to contact the Grants Management Specialist or Grants Officer’s Representative listed in the award document for information concerning individual awards.

SOURCE: USAMRAA Supplemental Guidance March 25, 2020, FAQs from COGR March 19, 2020

CDC

No guidance at this time

HHS-OSHA*

No guidance at this time

ACF

No Guidance at this time

AHRQ

No guidance at this time

SAMHSA

SAMHSA is currently reviewing requests to carryover unspent funds from discretionary grant recipients that submitted carryover requests at the end of their last budget period. Recipients should wait to receive a response to their carryover request before submitting a new request to reallocate carryover funding. Recipients should notify their GMS of their intent to modify their carryover request.

SOURCE: COVID-19 Information for SAMHSA Discretionary Grant Recipients

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No-Cost Extensions

NIH

Under the Standard Terms of award, recipients may extend the final year of the approved project period of an active grant up to 12 months. Affected recipients that have active non-SNAP awards may extend the final budget period of the approved project period of an active grant up to 12 months, without prior approval, by working with their RSC to notify the assigned grants management specialist.

To support participant health and safety, and continuity of research during this public health emergency, NIH will allow for additional extensions, including mid-project period extensions, for awards supporting NIH-funded clinical trials and human subjects research.

NIH will allow awards supporting clinical trials and other human subjects research to extend beyond the typical 7-year timeframe for extensions related to COVID-19.

SOURCE: NIH GPS 8.1.1.3, NIH FAQs, NOT-OD-20-086, NOT-OD-20-087

NSF

All NSF grants are eligible for a one-year recipient approved no-cost extension and then further extensions as approved by NSF. If you foresee a need for NSF-approved extensions, you should include that information in your annual report and discuss the need ahead of time with the cognizant NSF program officer for your award.

SOURCE: NSF COVID-19 FAQs and  (PAPPG), Chapter VI.D.3

DOD

It is DOD policy that no-cost extensions be supported in all possible cases; however, be please be aware that funding expiration statutes may prohibit extensions. Please contact the DOD grants manager for award-specific guidance.

 

SOURCE: FAQs for DOD Research Proposers and Awardees Impacted by COVID-19

DOD-USAMRAA

Recipients have the authority to extend the period of performance one-time up to 12 months beyond the original completion date stated in the award by working with your OSR Staff to notifying the Grant Officer once you have assessed how much additional time will be needed.

Recipients of multiple awards should work with their OSR Staff to notify Grants Officer of multiple awards that need an extension. Applicable grant numbers should be included in the notification.

Additional time beyond the initial 12 months requies prior approval. 

Please be aware that funding expriation status may prohibit extensions - recipients shoud contact the Grants Officer for award-specific guidance.

USAMRAA will extend flexibilities to awards that support efforts related to COVID-19 on a case-by-case basis. Please work with your OSR Staff to contact the Grants Management Specialist or Grants Officer’s Representative listed in the award document for information concerning individual awards.

SOURCE: USAMRAA Supplemental Guidance March 25, 2020, FAQs from COGR March 19, 2020

DAF-AFOSR The Air Force Office of Scientific Research (AFOSR) will allow recipients of awards impacted by COVID-19 that are active as of March 31, 2020 and scheduled to expire on or before December 31, 2020, to request a no-cost extension up to 12 months.
  • Requests must come from the institution’s business officer addressed to the Program Officer (using appropriate email), Grant Officer, and [email protected].
  • A grant modification will be issued by the Grant Officer.
  • The no-cost extension is not official until it is signed by the Grant Officer.
  • Awards expiring after December 31, 2020 that require a no-cost extension will be examined when the need arises.

SOURCE:  AFOSR Memorandum to Grantees 26Mar2020

CDC

Due to the impact of COVID-19, CDC may extend awards that were active as of March 31, 2020, and scheduled to expire prior or up to December 31, 2020, automatically at no cost for a period of up to 12 months. No-cost extensions will be considered on a case-by-case basis. When CDC provides no-cost extensions, this will allow time for recipient assessments, the resumption of many individual projects, and a report on program progress and financial status to agency staff. Project-specific financial and performance reports will be due 90 days following the end date of the extension. CDC will examine the need to extend other project reporting as the need arises. Recipients should work with  their RSC to reach out to their assigned grants management specialist/program official if they anticipate needing a no-cost extension.

SOURCE: Flexibilities Available to Applicants and Recipients Affected by COVID-19

HHS-OSHA*

No guidance at this time

ACF

Flexibilities are applicable to ACF applicants and recipients where the entity is conducting human service activities related to or affected by COVID-19. Affected entities are those that have been closed or that have business activities that are hindered due to COVID-19 precautionary measures and/or illnesses. Affected entities will be asked to provide documentation to the respective ACF Program Office describing the effects, including how long the program and ACF-related work or instruction were and/or will be affected.

If permitted by law  and at the discretion of appropriate Program Office, ACF will consider no-cost extension requests for awards active as of March 31, 2020 and scheduled to expire up to December 31, 2020, for a period up to 12 months, to allow time for recipient assessment, project resumption, and a report on program progress and financial status to ACF.

SOURCE: Administration for Children & Family IM-ACF-OA-2020-01

AHRQ

Recipients of awards made under expanded authorities are allowed a one-time no-cost extension of the final year, up to 12 months and should notify AHRQ if this allowance is exercised. Recipients of awards not made under expanded authorities should request prior approval for a no-cost extension of the final year. Please work with your OSR Staff to execute either action as required by the award.

SOURCE: NOT-HS-20-010

SAMHSA

SAMHSA understands that discretionary grant recipients are limited in their grant activities because of COVID-19. In these cases recipients should notify their GMS and GPO of their intent to submit a NCE. NCE forms are posted on the SAMHSA site.

SOURCE: COVID-19 Information for SAMHSA Discretionary Grant Recipients

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Expenditure of Award Funds for Salaries, Stipends and Other Project Activities

NIH

(New) NOSI NOT-CA-20-082 announces an opportunity for National Cancer Institute (NCI) Principal Investigators whose postdoctoral fellows have temporarily lost stipend support from a non-profit sponsor as a result of COVID-19.  This administrative supplement will support the postdoctoral fellow’s salary plus F&A for time and effort, up to 6 months, on active NCI funded grants and cooperative agreements in the area related to the focus of the postdoctoral fellow’s work. Due Dates:  rolling bases from July 6, 2020 through August 14, 2020.

Clarification: OMB Memo M-20-17 (expired) allowed recipients to charge NIH awards for costs directly related to the affected grant project. Salary supplementation for NRSA stipends is not a cost supported by an NIH project, and is not allowable. NIH remains committed to supporting and provi((ding maximum flexibilities to its recipients; however, in doing so, NIH must remove options that would pose audit risks for unallowable charges.

Clarification: Stipends and other expenses may not be charged to NRSA awards for trainees and fellows who have not yet been appointed and cannot travel to the U.S. to start work on their NIH-funded projects.

Clarification: Recipients may not initiate charges for salaries and benefits on new awards where the work has not yet started. Recipients may only charge salaries and benefits when no work is performed on currently active awards, when their organization’s current 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 the recipient’s performance site/facilities are open and/or telework options are available for work to begin, recipients may charge salaries and benefits to NIH grant awards.

Charging salaries and benefits to NIH grants when no work is being performed because of COVID-19 is allowable if the recipient 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/non-federal).

Recipient institutions should consult with their Human Resources Department to determine whether there are internal policies in place allowing employees to take paid leave, and to charge the grant, regardless of the source of funds, e.g. emergency or disruptive event policies. 

  • If your institution has such a policy and anticipates a need to charge personnel costs, please work with your OSR Staff to notify the funding IC. NIH may request documentation to confirm the requirements of the institutional policy and the effects of COVID-19.
  • Institutions affected by COVID-19 may continue to provide stipend payments to fellows and trainees who may be unable to work. Please work with your OSR Staff to notify  the assigned grants management official and provide documentation demonstrating the effect of COVID-19 and how long the institution is affected.

As a result of COVID-19, recipients conducting NIH-funded clinical trials and human subject studies may incur unanticipated costs (e.g. Costs incurred to arrange for participants to receive care at their local sites or virtually). Recipients should notify the funding IC of any changes necessary to maintain the health and safety of participants and staff. If unanticipated costs are identified due to impacts of COVID-19, and unobligated balances are not available to rebudget, recipients may request administrative supplements from the funding ICs (see PA-18-591 Administrative Supplements to Existing NIH Grants and Cooperative Agreements (Parent Administrative Supplement- Clinical Trial Optional).

While NIH ICs plan (based on availability of funds) to issue administrative supplements when absolutely necessary, such requests in the next 2-3 months would be premature. COVID-19 related administrative supplement requests should be submitted:

  • When the full impacts of the pandemic on the recipient's NIH supported research are clear
  • When the recipeint has had a chance to discuss the various options with relevant NIH staff and it was agreed that an administrative supplement is the best option for the project.

Exceptions to the above recommendations:

  • Supplements to existing projects that will allow investigators to immediately address scientific questions of direct relevance to the COVID-19 epidemic
  • Supplements that are needed to address immediate mission critical needs over the next 3 months.

Researchers that meet these exceptions should work with their OSR Staff to raise these issues with their program offiders and/or grants management specialist prior to submitting requests.

Recipients may donate personal protective equipment (PPE) and other lab supplies in support of efforts related to COVID-19. Recipients planning to do so shoudl work with their OSR Staff to provide assurances that the donated supplies are not being used for personal use and that the donation(s) will be documented for single audits and if NIH ICs request additioinal information.

Recipients should not assume the NIH ICs will provide additional funds to replace the donated PPE and supplies. Funding ICs should be consulted for specific details regarding supplemental support.

If project staff (including visiting faculty, postdoctoral scholars, scientists, etc.) leave the country to return home due to COVID-19 and continue to work on the project and continue to be paid by the project this would qualify as a foreign component and would require prior approval from the NIH IC.

If project staff is required to perform their originally approved work remotely from a foreign country due to COVID-19 travel restrictions, where no grant funds are going to a foreign entity, NIH has determined that this scenario does not fit the definition of a foreign component as outlined in the NIH Grants Policy Statement  (i.e. the performance of a significant scientific element or segment of the project outside of the US.

SOURCE: NIH FAQs, NOT-OD-20-086, NOT-OD-20-087, COGR OUTREACH, OMB M-20-17, OMB M-20-18NOT-CA-20-082

NSF

NSF implementation of  OBM M-20-26 Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance until September 30, 2020.

Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active NSF awards consistent with the recipient’s policy of paying salaries under unexpected or extraordinary circumstances, from Federal and non-Federal sources. Recipients are authorized to charge other costs, consistent with the Federal cost principles, that are necessary to resume activities supported by the award; however, recipients must not assume that supplemental funding will be available should the charging of these costs result in a shortfall of funds. If a shortfall is anticipated, recipients must work with their OSR Staff to contact the cognizant NSF Program Officer to discuss the situation.

NSF will evaluate the grantee’s ability to resume project activity in the future and appropriateness of future funding, based on subsequent project reports and other communications with the recipient. 

Payroll costs paid with the Paycheck Protection Program (PPP) loans or any other Federal Coronavirus Aid, Relief, and Economic Security (CARES) Act programs must not be charged to current NSF awards.

Recipients are reminded of their responsibility to maintain appropriate records and cost documentation  to substantiate any salaries and other project costs related to interruption of operations or services as required by 2 CFR 200.302 and 2 CFR 200.333.

Due to the limited funding resources under each NSF award necessary to achieve its specific project, as specified in M-20-26, recipients must 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 NSF funds for the ramp-up effort. Recipients must retain documentation of their efforts to exhaust other funding sources and reduce overall operational costs.

SOURCE: NSF Implementation of OMB M-20-17, OMB M-20-17, NSF Implementation of OMB M-20-26, OMB M-20-26 

DOD

Based on OMB Memorandum M-20-17 and the Uniform Guidance, DOD will allow recipients to continue to charge salaries and benefits to currently-active awards consistent with the recipient’s policy for paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal or non-Federal. DOD components may allow other costs to be charged necessary to continue work on a project even during a period where primary research activities are limited or curtailed. 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. Recipients will be expected, to the maximum extent practicable, to institute reasonable mitigation actions and practices to lessen the cost to the government during the crisis period.

 

SOURCE: FAQs for DOD Research Proposers and Awardees Impacted by COVID-19

DOD-USAMRAA

Recipients may 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.

USAMRAA will allow charging other costs that are necessary to resume award activities, consistent with applicable Federal cost principles and to the benefit of the project. This may include allowing rent on equipment and facilities during this time frame; however, recipients must institute 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 organization or may be created to respond to the crisis.

Recipients must 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.

USAMRAA will extend flexibilities to awards that support efforts related to COVID-19 on a case-by-case basis. Please work with your OSR Staff to contact the Grants Management Specialist or Grants Officer’s Representative listed in the award document for information concerning individual awards.


The following guidance was added April 30, 2020 to incorporate M-20-20:

Change of grant/cooperative agreement purpose or scope in whole or in part to support COVID-19 response:

  • Recipients may not repurpose the entire amount (or remainder) of the award to COVID-19 response activities.
  • Donation of medical equpment, personal protective equipment, medical devices, medicines, and other medical equipment
    • Must first have prior approval from the Grants Officer
    • If approved recipient must maintain apropriate records and documentation of these exceptions.
    • Recipients are advised that they should not assume additional funds will be available for their grant/cooperative agreement should the donations or repurposing of funds result in any type of shortage.
  • Donation of other resources (e.g. labor, supplies, contract services)
    • Must first have prior approval from the Grants Officer
    • If approved recipient must maintain appropriate records and documentation of these exceptions
    • Recipients are advised that they should not assume additional funds will be available for their gant/cooperative agreement should the donations or repurposing of funds result in any type of shortage.
  • Appropriated funding authorities and agency delegations stipulate that assistance agreements must support biomedical research and development. Appropriations with Congressional direction must remain within scope of that direction.
  • Recipients who whish to repurpose the aims of a current grant/cooperative agreement to focus specifically on COVID-19 research must contact the Grants Officer or Grants Officer's Representative to discuss a change in scope. Approval of such changes; however, may be limited by the appropriation/legislative authority or program considerations. NOTE: the U.S. Army Medical Research and Development Command's Congressionally Directed Medical Research Programs recently released new FY20 Peer Review Medical Research Program Funding Opportunities focused on COVID-19 and SARS-CoV-2 in the two topic areas "emerging viral diseases" and "respirtory health."

NOTE: This guidance does not apply to contracts. For information pertaining to USAMRAA contracts see the resources posted under "Contracting" on the USAMRAA COVID-19 Resources page.

 

SOURCE: USAMRAA Supplemental Guidance March 25, 2020, FAQs from COGR March 19, 2020, OMB M-20-17, USAMRAA Supplemental Guidance Appril 30, 2020

CDC
  • Recipients may continue to charge salaries and benefits to currently active federal awards consistent with the recipient’s policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal. Recipients' pay policy must be applied consistently to all current staff, regardless of the funding source. Recipients are required to maintain records and documentation to substantiate the charging of any salaries and other project activities costs related to the interruption of operations or services, including reference to the recipients’ salary policy. Concurrent with programs, recipients will need to assess the impact on their programmatic activities that were originally funded once normal activities resume. Recipients should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds.
  • Allowability of salary is different from temporary reassignment of personnel. For information on temporary reassignment of personnel, please review the temporary reassignment webpage.
  • Recipients may charge costs to the award such as the cancellation of events, travel, or the pausing and restarting of grant-funded activities due to the public health emergency. Recipients are required to maintain records and documentation to substantiate the costs incurred. Recipients should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds. Any cost that is reimbursed to recipients (e.g., canceled airline tickets that are refunded through a voucher) needs to be accounted for by the recipient.

SOURCE: Flexibilities Available to Applicants and Recipients Affected by COVID-19 and FAQs

 

HHS-OHSA*

Recipients may continue to charge salaries and benefits to currently-active awards consistent with the recipient’s policy for paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal or non-Federal. Recipients may charge other costs necessary to resume activities supported by the award. The recipient’s ability to resume project activity in the future and the appropriateness of future funding will be evaluated based on subsequent progress reports and communications with the grantee.  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. Recipients should not assume additional funding will be available if the charges for salaries and other project activities results in an overall shortage of funds to complete the entire project. Waivers are granted until the public health emergency ends but no more than 90 days.

 

SOURCE: HHS Memo to Recipients of OASH Grants and Cooperative Agreements, OMB M-20-17

ACF

Flexibilities are applicable to ACF applicants and recipients where the entity is conducting human service activities related to or affected by COVID-19. Affected entities are those that have been closed or that have business activities that are hindered due to COVID-19 precautionary measures and/or illnesses. Affected entities will be asked to provide documentation to the respective ACF Program Office describing the effects, including how long the program and ACF-related work or instruction were and/or will be affected.

To the extent permitted by law, ACF will allow recipients to continue to charge salaries and benefits to urrently-active awards consistent with the recipient’s policy for paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal or non-Federal. Recipients will be permitted to amend/create emergency policies in order to pput emergency contingencies in place.

ACF will allow the charging of other allowable costs consistent with applicable Federal cost principles (e.g. program-related, allocable, reasonable), necessary to resume award activities that benefit the project. ACF will evaluate recipient's ability to resume project activity in the future and appropriateness of future funding as done under normal circumstances based on subsequent progress reports and communications with the recipient.

ACF will require recipient 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.

SOURCE: Administration for Children & Family IM-ACF-OA-2020-01

 

AHRQ

AHRQ Recipients may continue to charge salaries and benefits to currently-active awards consistent with the recipient’s policy for paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal or non-Federal.

Recipients may charge other costs necessary to resume activities supported by the award. The recipient’s ability to resume project activity in the future and the appropriateness of future funding will be evaluated based on subsequent progress reports and communications with the grantee.  

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.

SOURCE: NOT-HS-20-010, OMB M-20-17

SAMHSA

In general recipients may rebudget funds to other activities because of the current situation, as long as the activities are allowable under the FOA and in line with the statutory requirements of the award. Recipients should contact their GPO and GMS about any such repurposing of funds.

Grant recipients have flexibility to rebudget (25% of the current budget or $250,000 whichever is less) as long as rebudgeting includes activities that are allowable under the FOA, within the scope of the grant, and in line with the statutory requirement of the award. Recipients must keep documentation of all costs and SAMHSA may request this documentation during the grant period.

If the amount to be rebudgeted is greater than 25% of the current budget or $250,000 whichever is less, the recipient MUST submit a COVID-19 post award amendment through the eRA Commons (see sample revised budget to be used).

Recipients may switch from planned face-to-face service/training/meetings to conducting these activities virtually. If budget modifications are needed to do this, recipients should submit a revision request.

SAMHSA grant funds can be used to purchase Personal Protective Equipment (PPE) for authorized grant personnel working in service of the grant. SAMHSA grant funds cannot be used to purchase PPE for unrelated grant activities.

SAMHSA grant funds can be used to purchase laptops and other devices to deliver training and services specified under the grant, including the purchase of software to facilitate the delivery of services and training. SAMHSA grant funds cannot be used to purchase laptops and other devices for personal use or for clients. In addition, the purchasing of internet services for clients is not authorized.


SOURCE: COVID-19 Information for SAMHSA Discretionary Grant Recipients

 

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Delays in Research Progress Including Financial and Other Reporting

NIH
  • Recipients must report on the effects of COVID-19 on the NIH funded research in their next RPPR submission. Recipients are not to submit standard letters, these details must be submitted within the RPPR. The funding IC will consider the effects that are reported by the recipient when reviewing and approving the RPPR. 
  • If unable to submit financial and progress (RPPRs) reports by the scheduled due date or there are delays in research progress (e.g. meeting project milestones, delayed IRB approvals, low/stalled participant recruitment, etc.) due to the effects of COVID-19, please contact the assigned grant management and/or program official to let them know of the delay. NIH will accept late reports but will delay issuing grant awards until the reports are received and accepted by the awarding IC. Recipients can request funded extensions by contacting the funding IC. Principal Investigators should work with their RSC.
  • Recipients of NIH-funded clinical trials and human subject studies affected by COVID-19 should consult UCSF Directives to Clinical and Non-Laboratory Researchers about potential measures to protect participants and staff.
  • If UCSF facilities are closed due to COVID-19  and research labs and results cannot be maintained due to the closure. Before submitting requests for administrative supplements: the full impacts of the pandemic on the NIH-supported ressearch should be clear and recipients have worked with their OSR Staff  to contact relevant NIH staff to discuss various options and agreed that an administrative supplement isthe best option for the project.
  • If a delay in research progress is anticipated recipients may extend the final budget period of the approved project period on active grants one time for up to 12 months without seeking prior approval from the NIH (see no-cost extension).
  • NOTE:  NIH will allow for additional extensions including mid-project period extensions due to the effects of COVID-19 for awards supporting NIH-funded clinical trials and human subjects research; such recipients should work with  their RSC to contact the supporting IC.
  • CLOSEOUT REPORTS: If it is anticipated that there will be a delay in the submission of closeout reports (e.g. financial, performance, inventions, and other reports per the terms of award for the closeout of expired awards) due to the effects of COVID-19, under the standard terms of award, recipients may extend the final year of the project period up to 12 months (see No-Cost Extension). If award does not allow a no-cost extensin and additional time is needed, work with your OSR Staff to notify the funding IC and the NIH Closeout Center at [email protected] and provide a detailed justification on the effects of COVID-19 on the institution and grants where reporting will be delayed. Such delays may not exceed one year.
  • Recipients of NIH awards for supplemental funding from the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020 (PL 116-123), are not required to submit an RPPR for these activities, special reporting requirements will be included in the terms and conditions of the award for all awards issued using COVID-19 funds.  COVID-19 funds will be issued in separate subaccounts in the HHS Payment Management System, with a 'CV' suffix. In order to track these special appropriations, recipients will be required to submit separate Federal Financial Reports (FFRs) for these subaccounts.
  • COVID-related flexibilities for updating and correcting study information in ClinicalTrials.gov: though important to ensure accurate and up-to-date clinical trial information is available to the public on ClinicalTrials.gov, particularly for COVID-19 related research, NIH acknowledges that delayed updates and corrections may be unavoidable due to the impact of the public health emergency on research-related staff. Refer to Top Questions from Responsible Parties Related to COVID-19 for information on specific questions.
  • Foreign Postdoctoral Fellows on NIH-funded studies: if a foreign postdoctoral fellow is working in the U.S. on a NIH funded study and needs to return to his/her home country and will continue to work remotely on the study, this would qualify as a foreign component. If this is a consideration, please work with your OSR Staff to obtain prior approval to add a foreign component to the award and report as such on the RPPR.
  • Delays to phased Career Development awards, research training awards, and fellowships:
    • Phased awards (e.g. K22 or K99/R00) career development, research training awards and individual fellowships, that experience delays are allowed extensions by notifying the funding IC. Please work with your OSR Staff to prepare and submit such communications to the funding IC.
    • Recipients of phased Career Development awards (e.g. K99/R00) who are unable to transition to faculty position due to delays caused by COVID-19 should with their mentors contact the funding IC in writing to provide details of the delays. Please work with your OSR Staff to prepare and submit communications to the funding IC.

    • Due to the varying needs of T35 recipients, NIH will handle flexibilities for these awards on a case-by-basis. Please work with your OSR Staff to submit your request to the funding IC.
    • T32/T35 recipients may be able to carryover unused funds from the prior budget period. Please work with your OSR Staff to notify the funding IC.

SOURCE: NIH FAQs, NOT-OD-20-086, NOT-OD-20-087

NSF

Continuation requests consists of submission of the requisite annual project report in Research.gov as well as any award specific requirements. NSF does not require submission of a Federal Financial Reports for each award as financial data is extracted from the cash management system. NSF will continue to process daily grant payments to recipients without interruption.

NSF has automatically extended the due date by 30 days for all annual project reports due between March 1 and April 30, 2020. These reports must be submitted by the revised due date, via Research.gov. NSF cannot make any new awards or supplement an existing award if PIs or co-PIs have an overdue annual project report.

NSF has automatically extended the due date by 30 days for all final project reports and project outcome reports due between March 1 and April 30, 2020. These reports must be submitted by the revised due date via Research.gov. NSF cannot make any new awards or supplement existing awards if the PIs or co-PIs have an overdue final report.

NSF reminds recipients that prior approval requests must be submitted in Research.gov for any changes in scope or objectives of the project, change in principal Investigator or co-PI specified in the award, subawarding or transferring of any work (unless described in the approved proposal), or need for additional NSF funding to complete the project.

SOURCE: NSF Implementation of OMB M-20-17

DOD

Allows grantees to delay submission of financial, performance, and other reports for currently-active awards up to 3 months beyond the normal due date. For any other deliverables related to research awards, please contact the DOD grants manager and/or the DOD program manager for award-specific guidance.

It is DOD policy that no-cost extensions be supported in all possible cases; however, be please be aware that funding expiration statutes may prohibit extensions. Please contact the DOD grants manager for award-specific guidance.

 

SOURCE: FAQs for DOD Research Proposers and Awardees Impacted by COVID-19

DOD-USAMRAA
  • Recipients may delay submission of financial, performance and other reports on currently active award accounts up to 3 months beyond the normal due date.
  • Contact the Grant Officer and Grants Officer’s Representative (GOR) for extensions on other milestones and deliverables required in the terms and conditions of the award. If warranted, the same 3 month extension may be granted.
  • Recipients may continue to invoice for payment of Federal funds without timely submission of reports
  • Reports must be submitted at the end of the postponed period. Additional extensions require prior approval of the Grant Officer.
  • Recipients may delay submission of any pending financial, performance and other reports required by the terms of the award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the grantee to the Grant Officer.
  • This delay in submitting closeout reports may not exceed one year after the award expires.

USAMRAA will extend flexibilities to awards that support efforts related to COVID-19 on a case-by-case basis. Please work with your OSR Staff to contact the Grants Management Specialist or Grants Officer’s Representative listed in the award document for information concerning individual awards.

If the effects of COVID-19 impact the conduct of a DoD-supported human subjects research protocol, recipient should seek local guidance from their IRB and notify the USAMRAA Human Research Protection Office (HRPO) in the following circumstances:

  • Substantive amendments require HRPO review and approval prior to implementation. HRPO will not require pre-approval of amendments intended to minimize the risk of COVID-19 exposure for study participants or study team members; follow local IRB review and approval and forward documents to HRPO via email at: [email protected]
  • Unanticipated problems involving risks to subjects and others, which include inadvertent exposure of research subjects or study personnel to COVID-19, missed or delayed safety assessments due to pandemic, inability to provide study product or conduct key research interventions. These should be promptly reported to the reviewing IRB and to HRPO via email at: [email protected]
  • Promptly report any actions taken to halt the conduct of ongoing human subjects research (e.g. pausing new enrollment, canceling follow-up procedures for previously enrolled subjects, etc.) due to the pandemic. Principal Investigators should review UCSF Interim Policy on Human Subjects-Related Research and contact HRPO via email at: [email protected] to notify them of the University’s policy and make appropriate arrangements. UCSF is not contacting sponsors centrally at this time. See the open letter to research sponsors and collaborating institutions.
  • Recipients must adhere to all other reporting and submission requirements specified in their HRPO approval memorandum.

SOURCE: USAMRAA Supplemental Guidance March 25, 2020, HRPO FAQs, FAQs from COGR March 19, 2020

CDC
  • Due to the impact of COVID-19, CDC may accept a brief statement from recipients for continuation requests scheduled to come in from April 1, 2020, to December 31, 2020, for projects with planned future support. CDC programs will post any specific instructions in their continuation guidance. CDC will use the brief statements to verify that recipients are in a position to resume or restore their project activities and accept a planned continuation award. CDC may examine the need to extend this approach on subsequent continuation award start dates as recipients have an opportunity to assess the situation.
  • On a case-by-case basis, CDC may allow recipients to delay submission of financial, performance, or other reports up to 3 months beyond the normal due date. These extensions are for reporting requirements due within the 90-day time period of the OMB Memorandum M-20-17. A recipient should work with  their RSC to reach out to their assigned grants management specialist/program official if they anticipate needing an extension. Determinations will be made based on recipient need and assessment of recipient’s previous progress reports, and any potential impacts on future funding amounts and awards. If CDC allows such a delay, recipients will continue to draw down federal funds without the timely submission of these reports. However, these reports must be submitted at the end of the extension.

SOURCE: Flexibilities Available to Applicants and Recipients Affected by COVID-19 and FAQs

HHS-OASH*

If recipient are able to make temporary modifications of activities to accomplish project goals, a request for a change in scope must be submitted through Grant Solutions and approved by a Grants Management Officer. If the request states that the change is temporary and a result of COVID-19, the project scope will automatically revert back to the previously approved project (e.g. no request is required to return to the original scope). Recipients who are unable to conduct award activities during the public health emergency do not need to submit a request to change the scope or to rebudget. Instead, they should notify the Grants Management Specialist and Federal Project Officer listed on the Notice of Award that cessation of award activities has occurred. The request may be sent through Grant Solutions or via email. Prior approval is not required to resume project activities that had ceased. Recipients are responsible for reporting specific COVID-19 impacts that led to any cessation of project activities in their progress report for the affected period. Recipients should not assume additional funding will be available to offset the impacts of COVID-19 or to resume award activities to complete the project.  Waivers are granted until the public health emergency ends but no more than 90 days.

SOURCE: HHS Memo to Recipients of OASH Grants and Cooperative Agreements

ACF

Flexibilities are applicable to ACF applicants and recipients where the entity is conducting human service activities related to or affected by COVID-19. Affected entities are those that have been closed or that have business activities that are hindered due to COVID-19 precautionary measures and/or illnesses. Affected entities will be asked to provide documentation to the respective ACF Program Office describing the effects, including how long the program and ACF-related work or instruction were and/or will be affected.

For continuation requests scheduled from April 1, 2020 to December 31, 2020 for projects with planned future support, ACF will accept a brief statement from recipients verifying that they are inn a position to: 1) resume or restore project activities; and 2) accept a planned continuation award. ACF will post any specific instruction on their website at: https://www.acf.hhs.gov/coronavirus. ACF will examine the need to extend this approach on subsequent continuation award start dates as recipients have an opportunity to assess their situation.

ACF will allow recipients to delay submission of financial, performance, and other reports up to 3 months beyond the normal due date. Recipients may continue to draw down Federal funds without the expected submission of these reports; however, reports must be submitted at the end of the postponed period. recipients must continue to notify the agency of problems, delays or adverse conditions, including those related to COVID-19 as required by 2 CFR 200.328(d)(1).

ACF will allow the recipient to delay submission of any pending financial, performance, and other reports required for closeout of expired projects, provided that proper notice about the reporting delay is given to the agency. This delay may not exceed one year after the award expires.

SOURCE: Administration for Children & Family IM-ACF-OA-2020-01

AHRQ

AHRQ will allow submission of financial, performance and other reports, except annual RPPRs, up to 3 months beyond the normal due date. AHRQ recipients should follow standard procedures and due dates for submitting Research Performance Progress Reports (RPPRs) to request non-competing continuation support on time. Delays in submission of the RPPR will delay these awards. AHRQ will consider requests for reasonable extensions of RPPR due dates on a case-by-case basis. Please work with your OSR Staff to contact the Grants Management Specialist named on the most recent NOA.

AHRQ cautions recipients of awards that are awarded using fiscal year appropriations that will expire September 30, 2020.

AHRQ will allow delay in the submission of pending financial, performance and other reports required by the terms of the award for the closeout of expired projects.  Please work with your OSR Staff to notify the Grants Management Specialist named on the most recent NOA of the delay well in advance of report due dates. This delay in submitting closeout reports may not exceed one year after the award expiration date.

Principal Investigators (PIs) should work with their OSR Staff regarding any changes that may need to be made to a study’s design and/or timeline. If it is determined that AHRQ prior approval or review is needed, formal requests should submit to the Grants Management Specialist named on the most recent NOA by your OSR C&G Officer. AHRQ does not waive the requirement for recipients to notify the agency of problems, delays, or adverse conditions related to COVID-19 on a grant-by-grant basis

 

SOURCE: NOT-HS-20-010

SAMHSA

Intake, follow-up, reassessment, or discharge data (GPRA/NOMS) may be collected telephonically or electronically.

Data (GPRA/NOMS) collection targets should not be changed as a result of the public health emergency. SMHSA will review data with the lens of the current emergency situation.

Grant recipients should make every effort to safely collect data. SAMHSA understands there are challenges to collecting data during the public health emergency and will take into account the period of time in which there was an emergency, which prevented the collection of data.

If recipients are able to collect data but not in the timelines provided by SAMHSA, they should collect and submit the data to SAMHSA.

SAMHSA will allow flexibility to discretionary grant recipients in the submission of required reports (e.g. progress reports, FFR, and closeout related reports), although recipients are encouraged to submit reports in a timely manner.

SAMHSA is automatically providing a 60 day extension to the deadline of reports due on or before April 30, 2020.

SAMHSA will also provide flexibility as needed to later due dates.

SOURCE: COVID-19 Information for SAMHSA Discretionary Grant Recipients

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Travel Costs

NIH
  • Non-refundable costs associated with grant-related travel that has been cancelled due to COVID-19 may be charged to the NIH award. (NIH GPS 7.9.1) If higher travel costs are experienced due to higher inflated markets, recipients should follow the UC Travel Policy to determine allowability of these costs in cases of unforeseen or emergency circumstances. To determine if travel is essential please consult the UCSF interim travel policy.
  • Non-refundable registration fees for conferences, symposiums or seminars that have been canceled due to COVID-19 may be charged to the NIH award if they are necessary to accomplish program objectives.
  • NIH-supported meetings or conferences may be delayed or canceled due to COVID-19. Non-refundable costs associated with meetings or conferences affected by COVID-19 are allowable and may be requested from the appropriate IC as an administrative supplement. Affected Principal Investigators should work with their RSC to contact the grants management and program officials to provide documentation demonstrating the effect of COVID-19. Awarding ICs will consider these requests on a case-by-case basis.
  • As this Public Health Emergency continues, recipients may identify additional cost-related flexibilities. NIH will consider requests on a case-by-case basis. Recipients should contact assigned grants management and program officials and provide detailed justification outlining the effect of COVID-19 and flexibility required.

SOURCE: NIH FAQs, NOT-OD-20-086, OMB M-20-17

NSF

Recipients who incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to the public health emergency, are authorized to charge these costs to their award. Recipients may charge the full cost to the award when the event, travel, or other activity is conducted under the auspices of the grant; however, recipients must not assume that supplemental funding will be available should these charges result in a shortage of funds to eventually carry out the event or travel. If a shortfall is anticipated, recipients must work with their OSR Staff to contact the cognizant NSF Program Officer to discuss the situation. Recipients are required to maintain appropriate records and cost documentation to substantiate the charging of any cancellation or fees related to interruption of operations or services (2 CFR § 200.302 Financial management and 2 CFR § 200.333 Retention requirements).

Recipients are reminded that a prior approval request must be submitted in Research.gov if they wish to transfer funds budgeted for participant support costs to other categories of expense.

SOURCE: NSF Implementation of OMB M-20-17

DOD

The DOD will allow nonrefundable travel expenses incurred for travel canceled due to COVID-19 to be charged to active awards in agreement with OMB Memorandum M-20-17.  Grantees must follow applicable institution policy on allowable expenses for travel.

SOURCE: FAQs for DOD Research Proposers and Awardees Impacted by COVID-19

DOD-USAMRAA

USAMRAA will allow recipients who incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to the public health emergency, to charge these costs to their award without regard to 2 CFR § 200.403, Factors affecting allowability of costs, 2 CFR § 200.404, Reasonable costs, and 2 CFR § 200.405, Allocable costs. Recipients should work with their OSR Staff to contact the cognizant USAMRAA grants official named in the award to alert them of the circumstances.

For meetings that are specified directly in the application or award notice, or that have been required by the CDMRP (e.g. milestone meetings, in-progress reviews, etc.), USAMRAA is open to rescheduling the meeting or setting up virtual presentation. Please work with your OSR Staff to notify the cognizant USAMRAA grants official named in the award.

USAMRAA will allow recipients to charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant.

However, recipients should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel.

 Recipients are required 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 cancellation or other fees related to interruption of operations or services.

USAMRAA will extend flexibilities to awards that support efforts related to COVID-19 on a case-by-case basis. Please work with your OSR Staff to contact the Grants Management Specialist or Grants Officer’s Representative listed in the award document for information concerning individual awards.

To determine if travel is essential and travel guidance during the public health emergency please consult the UCSF Interim Travel Policy.  Additional information is also available at these sites:

SOURCE: USAMRAA Supplemental Guidance March 25, 2020, FAQs from COGR March 19, 2020, OMB M-20-17

CDC Recipients may charge costs to the award such as the cancellation of events, travel, or the pausing and restarting of grant-funded activities due to the public health emergency. Recipients are required to maintain records and documentation to substantiate the costs incurred. Recipients should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds. Any cost that is reimbursed to recipients (e.g., canceled airline tickets that are refunded through a voucher) needs to be accounted for by the recipient.

SOURCE: Flexibilities Available to Applicants and Recipients Affected by COVID-19 and FAQs

HHS-OHSA*

Recipients may charge costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award or the pausing and restarting of grant activities due to the public health emergency. The full cost of cancellation may be charged when activities are conducted under the auspices of the grant. 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. Recipients should not assume additional funding will be available if the charges for cancellations or other fees results in an overall shortage of funds to carry out the event or travel. Waivers are granted until the public health emergency ends but no more than 90 days.

SOURCE: HHS Memo to Recipients of OASH Grants and Cooperative Agreements

ACF

Flexibilities are applicable to ACF applicants and recipients where the entity is conducting human service activities related to or affected by COVID-19. Affected entities are those that have been closed or that have business activities that are hindered due to COVID-19 precautionary measures and/or illnesses. Affected entities will be asked to provide documentation to the respective ACF Program Office describing the effects, including how long the program and ACF-related work or instruction were and/or will be affected.

To the extent permitted by law, recipients who incur costs related to cancellation of events, travel, or the pausing and restarting of grant-funded activities due to the public health emergency, to charge these costs to their awards. ACF will 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 costs incurred. Recipients should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event, travel and/or other activities.

SOURCE: Administration for Children & Family IM-ACF-OA-2020-01

AHRQ

AHRQ Recipients may charge costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award or the pausing and restarting of grant activities due to the public health emergency. The full cost of cancellation may be charged when activities are conducted under the auspices of the grant.

It is expected that recipients will attempt to have cancellation fees waived under any flexibilities vendors are allowing due to COVID-19. Recipients should not assume additional funding will be available if the charges for cancellations or other fees results in an overall shortage of funds to carry out the event or travel. Recipients should work with their OSR Staff to contact the Grants Management Specialist named on the most recent NOA to alert them of the anticipated shortfall.

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.

SOURCE: NOT-HS-20-010, OMB M-20-17

SAMHSA

Recipients may charge costs incurred that are related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award due to COVID-19.

If engaged in a contract with a provider or vendor, adhere to the contract’s cancellation terms as appropriate.

Recipients should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel.

Recipients are required to maintain appropriate records and cost documentation to substantiate the charging of any cancellation or other fees related to interruption of operations or services.

SOURCE: COVID-19 Information for SAMHSA Discretionary Grant Recipients, OMB M-20-17

*Office of the Assistant Secretary of Health/Grants Acquisition Management (OASH GAM) granted waivers until the public health emergency ends but no more than 90 days, for grants and cooperative agreements supported by:

  • Office of Population Affairs (OPA)
  • Office of Minority Health (OMH)
  • Office of Women’s Health (OWH)
  • Office of Research Integrity (ORI)

 

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Impact to Research Funding

 

Office of Management and Budget

*Note: These are from the OMB to the federal agencies, we a summary of agencies implementation is above in the Sponsor Guidance Section.   

CDC

DOE

FDA

NASA

NIH (Notices from the Office of the Director are summarized in the Sponsor Guidance Section above)

NSF  (Guidance below are summarized in the Sponsor Guidance Section above)

HHS-OASH GAM - Office of the Assistant Secretary of Health, Grants Acquisition Management (Guidance below is summarized in the Sponsor Guidance Section above)

HHS Memo to Recipients of OASH Grants and Cooperative Agreements

Administration for Children& Families (ACF) Information Memorandum: IM-ACF-OA-2020-01 ACF grant flexibilities in conducting human service activities related to or affected by COVID-19.

AHRQ - Agency for Healthcare Research and Quality (Guidance below is summarized in the Sponsor Guidance Section above)

SAMHSA - Substance Abuse and Mental Health Services Administration (Guidance below is summarized in the Sponsor Guidance Section above)

DOD - Office of the Under Secretary of Defense for Research & Engineering, Basic Research-Research Directorate (Guidance below is summarized in the Sponsor Guidance Section above)

USAMRAA - United States Army Medical Research Acquisition Activity  (Guidance below are summarized in the Sponsor Guidance Section above)

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Funding Opportunities related to COVID-19

Please notify your RSC of any intention to submit a proposal ASAP.  

 

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Additional Resources 

 UCSF Resources:

UC Resources: 

Council on Governmental Relations (COGR) Resources: 

Other 

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