Updated: 6 May 2020
Post Award Fiscal Compliance is actively monitoring Sponsor websites and news releases for information on impacts from COVID-19. Follow the instructions provided by the Sponsor or contact the Sponsor in writing for information. Contact PAFC (email@example.com) if you need any assistance.
There is no single announcement or guideline from the Federal Government regarding COVID-19. Instead, the Federal Office of Management and Budget (OMB) has released notifications to Federal Agencies (not recipients such as the UW) that identify areas of flexibility or “Administrative Relief.” Each Federal Agency determines whether to implement any of the areas of flexibility or relief identified by OMB.
Each Federal Agency's regulations should be reviewed to determine if any changes have been made due to COVID-19. The Council on Governmental Relations (COGR) is maintaining an excellent webpage that has links to all Federal Agencies' information on regulatory or policy changes due to COVID-19. COGR also has a useful Federal Agency Matrix. As the regulatory situation is rapidly changing, we recommend that you monitor your Federal Sponsor's information on a daily basis.
We provide a listing and analysis of the OMB notifications issued on COVID-19. We also provide separate webpages to assist in understanding individual cost items or administrative actions.
The two types of Federal Awards are governed by different Federal Regulations:
- Assistance Agreements (Grants): Code of Federal Regulations (CFR)
- Contracts: Federal Acquisition Regulation (FAR)
OMB has issued different notices for the two types of Awards:
Assistance Agreements (Grants):
OMB Memo 20-20 "Repurposing": This notice allows for Federal Agencies to repurpose funds from existing research Awards to support the COVID-19 response. Review each Agency's specific notifications for more information.
OMB Memo 20-17 "Administrative Relief": This notice outlines a framework of areas where individual Federal Agencies may provide Administrative Relief. We have analyzed OMB's Framework and how it applies to UW units.
OMB Memo 20-18 "Performance": This notice allows for Federal Agencies to work with their contractors (recipients) to accommodate teleworking, extend contracts affected by COVID-19 disruptions, modify contract scopes of work, and ease procurement requirements. Review the individual Federal Agency Sponsor regulations to determine which, if any, of these flexibilities have been adopted by the Federal Sponsor.
OMB Memo 20-22 "Resilience": This notice allows for Federal Agencies to allow extended use of paid leave time in order to retain employees who are unable to perform their duties due to the COVID-19 emergency. Follow the guidelines on PAFC's webpage on salary expenses under COVID-19 for more information.
For information relating to travel cancellations and changes due to COVID-19, please see Travel Reimbursement: COVID-19.
For more information on salary costs, please see Salary Expenses: COVID-19.
For available information on specific costs other than salary and cancelled travel, please see Other Costs: COVID-19. This page also has information on donating PPE and other supplies purchased on Sponsored Awards to COVID-19 efforts.
Prior Approval Waivers
Click here for more information on Prior Approval Waivers issued by some Federal Agencies.
While Federal Agencies are providing some flexibility and Administrative Relief, the following still apply:
- Review the Award and Sponsor requirements. The terms of the Award are applicable unless they are modified by the appropriate Sponsor authority or by changes to the Sponsor regulations.
- Maintain written communication with the Sponsor. If you communicate by other means, send a follow-up email that documents the communication.
- All costs must still meet the four cost principles (allowable, allocable, reasonable, and consistently treated).
- Award recipients are still expected to maintain appropriate records and cost documentation as required under Federal regulations. Given the exceptional circumstances surrounding the COVID-19 emergency, care should be taken to document costs which may otherwise appear unusual or questionable. Audits typically happen years after a cost was incurred and at that time, the effects of COVID-19 will not (hopefully) be as all-encompassing as they are now.
- While Federal Agencies are allowing administrative relief for costs that were already incurred, departments should avoid incurring additional costs (e.g., travel, supplies) until it is known when normal activities may resume. There is no guarantee that Federal Sponsors will provide supplemental funding to cover additional costs incurred due to COVID-19.
- Unallowable costs do not become allowable if a Sponsor grants administrative relief due to COVID-19. For example, if an international flight was purchased on a Federal Award and that flight did not comply with the Fly America Act, the cost of the cancelled ticket is not allowable even if the Federal Agency now allows for costs related to cancelled travel.
As always, if you have any questions, please let us know: firstname.lastname@example.org.