Last Updated: March 26, 2020
- Department of Defense
- DARPA
- National Institutes of Health
- National Science Foundation
- NASA
- Department of Energy
- Department of Justice
- National Endowment for the Arts
- National Endowment for the Humanities
This resource provides, at-a-glance summary information communicated by Federal Agencies regarding flexibilities in administration of federally funded grants during the COVID-19 Emergency. This guidance is intended as an overview. Principal investigators should consult their OSP Contracting Officer regarding specific projects. Links to agency guidance with more detailed information are included.
This information changes daily, if not hourly, and this document offers a snapshot. Ultimately, the most up to date guidance will come from the federal agency making the award to Georgia Tech. The links provided to the Federal Agency websites lead to more detailed guidance and additional categories not covered herein.
Principal Investigators should contact the Office of Sponsored Programs for assistance with interpreting requirements. If information is not available from published sources, OSP will reach out to agencies with specific questions. We will add answers with broad applicability to FAQs, supplementing this document.
Please note that the use of the flexibility granted by an agency often requires that PIs or Georgia Tech provide documentation. These requirements are not covered here. PIs should check the agency guidance for details and contact their OSP Contracting Officer. Grantees and proposers are advised that each federal agency has different authorities, and there might not be complete uniformity between agencies, components of agencies, and even between programs. The safest course of action in all cases is to contact the grants manager and program officer for the award to determine how the financial assistance award will be treated.
All contents of this document are subject to change.
https://basicresearch.defense.gov/COVID-19/Frequently-Asked-Questions/ DoD Flexibilities
Charging Salaries: 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.
No Cost Extensions: It is DOD policy that no-cost extensions must be supported in all possible cases. However, please be aware that funding expiration statutes may prohibit extensions. Please contact the DOD grants manager for award-specific guidance.
Allowability / Charging Unusual Costs: (No Guidance)
Reimbursement of Canceled Travel Costs: DoD will allow nonrefundable costs for canceled travel to be charged subject to institutional policy. See applicable details and institution guidance.
Reports and Deliverables: Up to 3 months beyond deadline.
Proposal Deadlines: The DOD recommends that program offices provide flexibility with upcoming proposal deadlines to the extent allowable by funding authorities and by the need to have enough time for merit review of submitted proposals. Please contact the program officer and grants manager for the funding opportunity in question to seek an application deadline extension. Proposers are encouraged to monitor grants.gov to see if an extension has been posted.
https://www.darpa.mil/news-events/2020-03-19
Charging Salaries: (No Guidance)
No Cost Extensions: (No Guidance) see Reports and Deliverables below.
Allowability / Charging Unusual Costs: Yes such costs may be allowed although documentation of any incurred costs and any relevant facts and details about what caused them is required. Consult OSP and the detailed guidance.
Reimbursement of Canceled Travel Costs: DoD will allow nonrefundable costs for canceled travel to be charged subject to institutional policy. Each project is subject to and required to follow the terms and conditions of the specific procurement contract, grant, cooperative agreements, or Other Transaction, including any guidance on travel costs and reimbursement.
Reports and Deliverables: If projects are delayed due to COVID-19, the delay and impact to the project, what caused it, what has been done to mitigate the delay, and any other relevant facts and details must be documented. PIs should contact their OSP contracting officer as soon as possible. Georgia Tech must explain all facts and details of the situation, provide documentation, and note that COVID-19 is one of the reasons for the modification request.
Proposal Deadlines: Some deadlines are being changed. See individual programs for details.
https://grants.nih.gov/grants/natural_disasters/corona-virus.htm
https://grants.nih.gov/faqs#/covid-19.htm
Dr. Mike Lauer, NIH Deputy Director for Extramural Research, provides updates for the research community on flexibilities NIH is providing the community due to the COVID-19 public health emergency. The video can be found at https://www.youtube.com/watch?v=V5-Ry-2uGxs&feature=youtu.be
Charging Salaries: 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 Institute/Center (IC). NIH may request documentation to confirm the requirements of the institutional policy.
No Cost Extensions: Recipients can request funded extensions by contacting the funding IC.
Allowability / Charging Unusual Costs: The recipient institution should notify the funding IC of any changes necessary to maintain the health and safety of study participants and may request an administrative supplement to cover unanticipated costs.
Reimbursement of Canceled Travel Costs: Non-refundable costs associated with grant-related travel that has been cancelled due to COVID-19 may be charged to the NIH award if they would have otherwise been allowable. See NIH GPS 7.9.1 for detailed information on the allowability of travel expenses.
If vouchers have been granted for any of the travel expenses affected by COVID-19, recipients are required to use the vouchers and may not request additional support.
Institutions must document that costs charged to a grant are non-refundable and maintain documentation, in accordance with record retention requirements, and make them available to NIH upon request.
Reports and Deliverables: If the recipient anticipates delays, please discuss this with the funding IC.
NIH understands the potential effects of COVID-19 on the progress of NIH supported research. Recipients must contact the funding IC to alert them of any effects on the NIH funded research. NIH is committed to working with its applicants and recipients during this public health emergency. In addition, NIH recognizes that there may be delays in submission of RPPRs and other reports. See NOT-OD-20-086 for details on late submission.
Proposal Deadlines: NIH published a notice announcing that grant applications submitted late for due dates between March 9, 2020, and May 1, 2020, will be accepted through May 1, 2020. This notice applies to all relevant funding opportunity announcements, including those that indicate no late applications will be accepted. A cover letter providing a justification is not required. NIH will be extending the expiration date of most FOAs expiring between now and May 1. Be sure to read the notice carefully for details.
https://www.nsf.gov/news/special_reports/coronavirus/
https://www.nsf.gov/bfa/dias/policy/covid19/covid19_nsfombimplementation.pdf (Flexibilities)
Charging Salaries: Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active NSF awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources. Institutions are required to maintain appropriate records and cost documentation as required to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services.
No Cost Extensions: Recipients must follow standard policies and procedures specified in the NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter VI.D.3, and applicable award conditions regarding submission of grantee and NSF-approved no-cost extensions.
Allowability / Charging Unusual Costs: 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 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 may charge the full cost to the award when the event, travel, or other activity is conducted under the auspices of the grant.
Recipients are authorized to charge other costs to NSF awards that are necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project.
Recipients must not assume that supplemental funding will be available should the charging of such costs or other fees result in a shortage of funds to eventually carry out the project. If a shortfall is anticipated, recipients must contact the cognizant NSF Program Officer to discuss the situation. NSF will 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 project reports and other communications with the recipient.
Reimbursement of Canceled Travel Costs: See “Allowability” above.
Reports and Deliverables: NSF has automatically extended the due date for submission of all annual project reports due between March 1 and April 30, 2020, by 30 days. These project reports must continue to be submitted via Research.gov.
Recipients are reminded that NSF cannot make any new award or supplement any existing award, if the principal investigator (PIs) or any co-PI(s) has an overdue annual project report; therefore, it is vital that annual reports are submitted by the revised due date.
Proposal Deadlines: NSF has extended the deadline dates for specific funding opportunities. A listing of these extensions is available on the Foundation’s COVID-19 webpage. Deadline dates for funding opportunities that do not appear on the list remain unchanged. Recipients who are unable to meet stated deadlines should contact the cognizant NSF Program Officer to discuss the issue. NSF will consider extensions on a case by case basis.
Research Experience for Undergraduates (REU): Questions Regarding Research Experiences for Undergraduates (REU) Sites, Research Experiences for Teachers (RET) Sites, International Research Experiences for Students (IRES) Sites, and Similar Activities are answered at https://www.nsf.gov/bfa/dias/policy/covid19/covid19faqs_proposerandawardee.pdf.
https://science.nasa.gov/science-red/s3fs-public/atoms/files/SMD%20Message%20to%20Community.pdf
Charging Salaries: (No Guidance) From TownHall Memo: “We encourage all to continue to pay graduate students, post-docs, and lab staff”
No Cost Extensions: (No Guidance)
Allowability / Charging Unusual Costs: (No Guidance)
Reimbursement of Canceled Travel Costs: (No Guidance)
Reports and Deliverables: (No Guidance) From TownHall Memo: “We are anticipating impacts to solicitations and evaluations and will work with the research community to mitigate them”
Proposal Deadlines: (No Guidance) From TownHall Memo: “We are anticipating impacts to solicitations and evaluations and will work with the research community to mitigate them”
Charging Salaries: NASA is establishing Advance Agreements to identify the treatment of special or unusual costs covering employees who are unable to work remotely. NASA recognizes that some employees may not be able to perform NASA work remotely so NASA may allow for the placement of such employees under leave consistent with institutional policy and such leave may be an allowable cost under the contract and subject to provisional payment. This leave would be allowed solely for covering employees unable to work remotely because of this COVID-19 situation and keeping employees in a mobile ready state to maintain the Space Industrial Base and other skilled professionals and key personnel, per OMB Memo 20-18. Any costs provisionally paid under such circumstances will be subject to reconciliation and settlement as part of an equitable adjustment to the contract after a return to normal operations. Circumstances and conditions may vary according to contract type (terms and conditions and fixed-price vs cost reimbursement). Contact your OSP contracting officer as soon as possible. OSP will be providing guidance to individual PIs
https://science.osti.gov/grants/FOAs/Open
https://science.osti.gov/-/media/sc-1/pdf/2020/DOE_SC_Accommodating_Interuptions_to_Applicants-Awardees_due_to_COVID-19.pdf?la=en&hash=9725EC10F520C1EC8F56B5C2029640D205C95D4F
Charging Salaries: (No Guidance)
No Cost Extensions: (No Guidance)
Allowability / Charging Unusual Costs: (No Guidance)
Reimbursement of Canceled Travel Costs: Allowable. Subject to institution policies on nonrefundable travel purchases, etc.
Reports and Deliverables: If the lead PI is subject to closure or quarantine, then reports are to be competed as soon as practical. “Working from home... should not make it impossible to complete work or meet deadlines.” Discuss with Program Manager.
Proposal Deadlines: If the lead PI is subject to closure or quarantine, deadline may be extended by no more than 14 days. See details, and discuss with program manager. “Working from home... should not make it impossible to complete work or meet deadlines.” Discuss with Program Manager.
https://ojjdp.ojp.gov/funding/current
Charging Salaries: OJP will allow recipients to continue to charge salaries and benefits to their awards consistent with the recipients’ policy of paying salaries and benefits under unexpected or extraordinary circumstances from all funding sources (Federal and non-Federal). As outlined in 2 C.F.R. § 200.431 (a) and (b), benefits may include the costs of leave (“regular compensation paid to employees during periods of authorized absences from the job, such as for annual leave, family-related leave, sick leave … administrative leave, and other similar benefits”), as long as they are provided under written leave policies. OJP encourages recipients to review and update (if necessary) their written leave policies to address “unexpected or extraordinary circumstances.” Recipients are required to maintain copies of the leave policies and cost documentation (as required by 2 C.F.R. § 200.302, 2 C.F.R. § 200.333, and 2 C.F.R. § 431(b)(1)) to substantiate the charging of salaries and benefits during interruption of operations or services.
No Cost Extensions: In accordance with the Part 200 Uniform Requirements (2 C.F.R. Part 200, as adopted by DOJ) and consistent with the DOJ Grants Financial Guide, most OJP awards may be eligible for one no-cost extension of up to 12 months. If the grant has previously received a no-cost extension and an additional extension will be requested due to the extenuating circumstances occurring in connection with the public health emergency, refer to the DOJ Grants Financial Guide for additional information and consult with your grant manager as needed.
Allowability / Charging Unusual Costs: OJP 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 (e.g., the costs of providing telework equipment to employees who are working on the award), or the pausing and restarting of grant-funded activities due to the public health emergency, to charge these costs to their award.
OJP will allow recipients to charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant. In cases where charging of cancellation or other costs results in insufficient funds to eventually carry out the event or travel, please contact your grant manager to discuss possible alternatives or changes to the scope of the project, if feasible.
Reimbursement of Canceled Travel Costs: See above
Reports and Deliverables: For grantees unable to meet original due dates, OJP is allowing delayed submission of up to 60 days for progress and performance measure reports due in March and April 2020. GMS will continue to send automatic delinquency notifications, which can be disregarded.
Proposal Deadlines: Two week extension for deadlines between March 16 and March 31.
https://www.arts.gov/COVID-19-FAQs
Charging Salaries: You may transfer among direct cost line items in your budget without prior written approval from us. This means if your approved budget included salaries/wages or artist fees in your budget, you can direct your grant award money toward those costs. You must maintain documentation of all costs charged to the award.
No Cost Extensions: You can request a Period of Performance extension if you think you may be able to complete the project activities by a later end date. You also can request a change in the scope of the grant project. Depending on the change, you may be able to draw down funds for the costs and activities you’ve already completed.
Allowability / Charging Unusual Costs: If your organization incurs costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award due to the COVID-19 pandemic, you may charge these costs to your award. Awardees 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. If you have contracts with artists or other vendors, you must adhere to terms of the contract’s cancellation clause(s), as appropriate.
Reimbursement of Canceled Travel Costs: (No Guidance)
Reports and Deliverables: (No Guidance)
Proposal Deadlines: The Research Awards application deadline has been extended to help applicants dealing with the effects of COVID-19. (https://www.arts.gov/grants-organizations/research-awards)
These are the new dates:
Part 1 - Submit to Grants.gov
April 13, 2020 by 11:59 p.m., Eastern Time
Part 1 deadline has been extended.
Prepare application material so that it’s ready to upload when the Applicant Portal opens
Part 2 - Submit to Applicant Portal
April 16, 2020 at 9:00 a.m., Eastern Time, to April 23, 2020 at 11:59 p.m., Eastern Time
Part 2 dates to submit materials have been changed.
Earliest Announcement of Award or Rejection
November 2020
Earliest Beginning Date for National Endowment for the Arts Period of Performance
Research Grants in the Arts:
January 1, 2021
NEA Research Labs:
March 1, 2021
If you have questions about your application please contact nearesearchgrants@arts.gov
https://www.neh.gov/news/information-neh-and-covid-19
Charging Salaries: (No Guidance)
No Cost Extensions: We understand that COVID-19 may impact your funded project as activities may be postponed or cancelled. Please contact your project officer and grant management specialist through eGMS Reach so we can help you explore options such as extensions, budget revisions, and scope changes. The NEH Office of Grant Management will confer with program staff and formally convey approved changes to your award through eGMS Reach.
Allowability / Charging Unusual Costs: (No Guidance)
Reimbursement of Canceled Travel Costs: (No Guidance)
Reports and Deliverables: Current grantees can continue to access and submit materials as usual.
Proposal Deadlines: (No Guidance)