Updated: September 30, 2020
UPDATE:
The salary flexibilities outlined in OMB Memo 20-26 expired on September 30, 2020. Thus, the flexibilities outlined below could only be used if the federal agency that issued the Award has provided notification that it is allowing for the flexibilities and only for the period March 16, 2020 – September 30, 2020.
Here's a printable copy of the COVID-19 salary guidance as outlined below.
Step by Step Guidance
Some Sponsors have provided flexibility regarding how effort is expended on Awards that had already been received and work had begun but were disrupted due to COVID-19. The following Step by Step Guidance has been developed for departments to follow in the event of a work disruption for on-going Awards. This guidance is also applicable to summer salaries.
Step 1:
Every effort should be made to identify activities that:
- Can be performed remotely or in accordance with public health guidelines; and
- Relate to the Award objectives; or
- Further the relevant skills of the researchers on an Award.
This includes activities that are not expected to directly contribute to progress on the Award, such as reviewing materials, analyzing data, learning a related software program or other skill, or organizing and cleaning materials or data sets.
If researchers engage in these activities, their salaries can continue to be charged to the Award as usual.
Step 2:
In the event that no such activities can be identified, the department should consider reassigning researchers to other sources of funds. For example, there may be other Sponsored Awards that could take advantage of the effort provided by additional researchers. This is allowable as long as the Award has sufficient funds and, if necessary, the ability to re-budget to accommodate the additional effort. There may also be departmental or other unrestricted funding sources that could be utilized.
Step 3:
In the exceptional case that alternate work arrangements or reassignment cannot be identified:
- Sponsors may allow charging of salaries to an Award, even when the researcher is unable to work on that Award. Sponsors such as NIH and NSF (with requirements) have allowed this flexibility contingent on the UW issuing a Declaration of Extraordinary Circumstances. The UW has issued the declaration and an amendment. Review the Sponsor’s specific policies on COVID-19 to determine if the Sponsor allows for such flexibility and what the individual Sponsor requirements are for complying with their policy. For reference, COGR has compiled Federal Sponsors' COVID-19 policies. As the policies are changing frequently, always check your Sponsor's regulations before taking any action.
- If the Sponsor allows charging salaries when no work is being performed due to disruptions from COVID-19, time should be allocated to “Stay Home, Stay Healthy” pay per the HR webpage.
- If the Sponsor has not provided flexibility or has not issued guidance, work with OSP to seek sponsor approval prior to charging salary to an Award when a researcher is unable to work on the Award.
- If the Sponsor does not allow charging salaries when no work is being performed, then time should not be allocated to “Stay Home, Stay Healthy” and the researcher's effort cannot be allocated to that Sponsored Award. The researcher needs to work with their department and HR consultant to determine alternate funding or reduced effort.
Flexibility Guidelines
When exercising additional flexibility, please remember the following:
- There should be written communication with the Sponsor about the nature of the disruptions and the researchers’ activities. Federal Sponsors are being flexible about effort, but communication with the Sponsor is important to ensure they are aware of steps being taken to mitigate the effects of the disruption.
- The amount of salary to charge cannot exceed the level charged prior to the COVID-19 impact, and in any case, no more than the amount of salary commensurate with the effort level committed in the proposal or last progress report.
- Sponsors have indicated that charging salaries while researchers are unable to work may negatively impact the award by creating a budget shortfall. There is no guarantee that Sponsors will supplement with additional funding.
- If researchers have to quarantine, take care of a family member that must quarantine, or take care of a minor child, additional support is available. Please work with your HR consultant to determine other forms of available leave.
Resources
- Questions related to UW general HR policies? Consult UW HR.
- Questions related to UW academic HR policies? Consult UW Academic HR.
- Questions about Sponsored Awards? Consult OSP or PAFC.
FAQs
Q1: Does the above guidance apply only to UW researchers?
A: Yes, the guidance applies only to researchers and only if if no work can be done on the Award and there is no other work available.
Q2: To what categories of UW researchers does this guidance apply?
A: It may be applied to any UW researcher, including faculty, staff, postdoctoral scholars, and graduate student employees who were previously supported by the Award. In general, faculty, postdoctoral scholars, and graduate students should be able to continue work on their research remotely, even if progress on the Award is at a lower level than previously. In such cases, charges to the Award should continue as before and are not considered to fall under these guidelines.
Q3: Can salaries continue to be charged to internal UW research program funds, such as Bridge Funding and Royalty Research Funding?
A: Yes, if no work on the project can be done and there is no other work available.
Q4: If my progress on the Award has been impacted, is there any special documentation required?
A: Yes. Work with OSP to notify the Sponsor in writing of the impact of COVID-19 disruptions on the Award. Be sure to describe why the Award was impacted (e.g., lab closure, working from home requirement) and how progress has been impacted.
Q5: How do I determine whether or not a source of funding allows for charging salaries when no work can be done?
A: The Sponsor's regulations should be reviewed and/or the Sponsor should be contacted directly for guidance. A starting point could be a list of Federal Sponsors who have issued COVID-19 guidance but this list may not always be up date.
If the Sponsor has not issued guidance, contact the Office of Sponsored Programs (OSP) for assistance in reaching out to the sponsor. Charging of effort to an Award when no work can be done can only be done when the Sponsor has provided explicit approval or guidance.
Q6: Must I notify my Sponsor that I will be charging salaries when no work is being done?
A: Individual Sponsors have their own requirements for notification or approval; review the Sponsor’s guidance to determine the Sponsor’s requirements.
Q7: If I am redirected from research to clinical work to care for COVID-19 patients, can my salary still be charged to my research funding source?
A: Review the Sponsor’s regulations or work with OSP to contact the Sponsor directly for approval.
Q8: Will supplemental funding be available to "backfill" the cost of charging salaries when no work could be done, once the researcher is able to resume work on an Award?
A: Sponsors have not committed to future supplementation of Awards, although some are considering doing so. At this time, PIs should not assume that supplemental funds will be available and should instead make plans for completing the goals of the Award, such as reducing the scope or lengthening the timeline. PIs should work with OSP to obtain Sponsor approval for such Award modifications.
Q9: My research effort is covered by a Washington state budget. Can I continue to charge my salary to the state budget even if I cannot perform any work on my research?
A: Per the guidance above, every effort should be made to identify tasks associated with the research or that further the researcher’s relevant skill set. In the event that no tasks or alternate funding sources can be identified, contact your HRC for guidance.
Q10: My research effort was partially covered by an NIH grant and partially covered by a sponsor that does not allow charging of salaries when I am unable to work. Since it appears NIH will allow charging of salaries when I am unable to work, can I shift my entire salary to the NIH Award?
A: No. As mentioned above, the amount of salary charged to the NIH Award cannot exceed the level charged prior to the COVID-19 impact. Additionally the amount of salary charged to the NIH Award should be commensurate with the effort level committed in the proposal or most recent progress report.
Q11: Does this policy apply to researchers with salaries on gift budgets?
A: Yes. In this case, please check with your Advancement representative to ensure that the language of your gift agreement aligns with this policy.
Q12: I cannot work on an Award where my effort was Cost Share. Does my effort still count as Cost Share even though no work can be completed on the Award?
A: All Cost Share Contributions must be allowable expenses on an Award. If the Sponsor allows for effort to be charged to an Award when no work can be completed, then your effort can still be counted as Cost Share at the same level as before the COVID-19 disruption.
Q13: I have received a new Award but cannot start work on the Award due to the COVID-19 disruption. Can I still charge salaries on the Award per the guidance on this (PAFC COVID Salary) webpage?
A: Review the individual Sponsor’s policy to determine if they have issued a policy or guidance on effort on new Awards under these circumstances. If a Sponsor has not issued a policy, charges may be initiated only with explicit prior written approval by the Sponsor. NIH has issued guidance in their COVID-19 FAQs specifically disallowing charging salaries to new Awards where work cannot start. Sponsors should be consulted to determine if a delay in the Award start date would be appropriate.