Updated: January 14, 2021
Non-Federal Sponsored Awards
Follow the instructions provided by the Sponsor or contact the Sponsor in writing for information. Contact PAFC (gcafco@uw.edu) if you need any assistance.
Federal Sponsored Awards
There was no single announcement or guideline from the Federal Government regarding COVID-19. Instead, the Federal Office of Management and Budget (OMB) released memos to Federal Agencies that identify areas where the Federal Agencies can deviate from the standard Federal Regulations. It is up to each Federal Agency to determine whether to implement any of the deviations as outlined in the OMB Memos. The COGR website lists this information by Federal Agency.
As of October 1, 2020, all but one of the flexibilities has expired or been rescinded. The remaining flexibility has to do with Single Audit and SEFA reporting deadlines, both of which are managed by central UW departments.
Therefore, all flexibilities as identified below and on the PAFC webpages are available only within the specified timeframes.
The key OMB Memos are:
OMB Memo 20-20 "Repurposing": This notice allows for Federal Agencies to repurpose funds from existing research Awards to support the COVID-19 response.
OMB Memo 20-17 "Administrative Relief": This notice outlines a framework of areas where individual Federal Agencies may provide Administrative Relief; an analysis of this framework was completed by PAFC.
OMB Memo 20-26: Rescinded both the 20-17 flexibilities and 20-20 repurposing memos, so those actions are not allowable after June 16, 2020. The flexibilities on salary and costs incurred to resume research activities expired on September 30, 2020. If the OMB flexibilities have expired, then they are no longer eligible for federal agencies to implement.
Flexibilities Rescinded on June 17, 2020
The flexibilities outlined in OMB Memo 20-17 are eligible only for the period March 16, 2020 – June 16, 2020 as described in the pages listed below:
- Other Costs including donations to COVID-19 efforts and other supplies purchased on Sponsored Awards
- Travel Cancellations
- Prior Approval Waivers
As these flexibilities are time limited, and not all expenditures and refunds fall into this timeframe, we have a series of FAQs listed below.
Flexibilities Expired on September 30, 2020
The flexibilities outlined in OMB 20-26 are available only for the period March 16, 2020 – September 30, 2020:
- Salary costs: see PAFC's COVID salary page; and
- Costs necessary to resume Award activities.
For all of these costs, OMB provided the following guidance to charging of costs on an Award impacted by COVID:
- Retain documentation of efforts to exhaust other available funding sources to provide salary support.
- Implement necessary steps to save overall operational costs during the pandemic in order to preserve Federal funds for ramp-up, and document such steps.
- Maintain appropriate records and cost documentation (as required by 2 CFR § 200.302 and 2 CFR § 200.333) to substantiate the charging of any salaries and other Award costs related to interruption of Award implementation.
- Federal agencies may evaluate the recipient’s ability to resume Award implementation in the future and the appropriateness of future funding, as done under normal circumstances based on subsequent progress reports and other communications with the recipient.
The above conditions roughly translate into authorization for federal agencies to allow the charging of salaries per the flexibilities, but you should review those costs carefully to ensure that they are the best use of Award funds, document the rationale for expenditures of funds given the COVID impact, and do not expect that supplementary funding will be available to cover any additional costs due to COVID impacts.
We highly recommend that if your Award is impacted by COVID, you review the status of the Award with your Sponsor and obtain written Sponsor approval for any work plan or scope revisions.
As always, if you have any questions, please let us know: gcafco@uw.edu.
Audit Guidelines
Please see PAFC's audit guidelines for Awards which implemented flexibilities due to COVID-19.
FAQs on Timing of Flexibilities
For all scenarios listed below, the flexibility period is March 16 - June 16, 2020.
Allowable
- Within the flexibility period, I cancelled/asked for a refund and received a full or partial refund from the vendor (also within the flexibility period). Any non-refundable amount is an allowable expense as the request and refund was within the flexibility period.
- I cancelled/asked for a refund within the flexibility period but the vendor did not process my full or partial refund until after the flexibility period ended. As long as there is documented communication showing that the cancellation/refund request was made and the vendor agreed within the flexibility period, any non-refundable amount is allowable.
Unallowable
- No action was taken to cancel/request a refund during the flexibility period. If the request for cancellation/refund is made after the flexibility period, any non-refundable amount would not be an allowable expense.
Request Sponsor Approval
- I cancelled/requested a refund during the flexibility period but the vendor did not respond before 16 June or has not yet responded. Because the vendor did not take action during the flexibility period, it is not clear from the federal regulations if the non-refundable amount would be an allowable expense. Contact the Sponsor for guidance or approval to charge the non-refundable costs in this scenario.
- A conference or other work travel is required but the traveler is not comfortable traveling due to the risk of contracting COVID. Non-refundable travel costs (except for non-refundable airfare on federal awards) can be charged to the Award in accordance with UW Travel’s Health and Safety policy. Contact the Sponsor for guidance or approval to charge any other (non-travel) non-refundable costs to the Award.
As always, if you have any questions, please let us know: gcafco@uw.edu.