COVID-19 Federal Sponsor Expense Guidance

Mon, 13 Apr 2020 13:06:10 -0400

The Office of Management and Budget (OMB) released memorandum M-20-17,"Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations"). Each federal sponsoring agency must implement this memorandum and provide relevant guidance for UMBC grant-supported activities affected by COVID-19.

The following information is a summary of many federal agency guidelines for select expenditures. As the COVID-19 emergency continues to evolve, please review each sponsor’s specific guidance to ensure you are properly charging awards. The Council on Governmental Relations (COGR) has one of the most comprehensive sites for COVID-19 resources (https://www.cogr.edu/institutional-and-agency-responses-covid-19-and-additional-resources) with links to many federal agency specific guidance on federal award impact.

Salaries:

Many researchers and staff may be unable to work as a result of, or related to, the effects of COVID-19. If a recipient organization's policy allows for the charging of salaries and benefits during periods when no work is performed due to the effect of COVID-19, regardless of the funding source, including federal and non-federal, then such charges to grant awards will be allowable.

Note: Awarding agencies and/or auditors from the Office of Inspector General may request documentation to confirm the requirements of institutional policies. UMBC Updated Guidance on Remote Work and Leave provided by Human Resources supports administrative leave to be charged to awards.

Stipends:

Institutions affected by COVID-19 may continue to provide stipend payments to fellows and trainees who may be unable to work as a result of, or related to, COVID-19. Recipients should notify the assigned grants management official and provide documentation demonstrating the effect of COVID-19 and how long the institution will be affected.

Travel:

Non-refundable costs associated with grant-related travel that has been canceled due to COVID-19 may be charged to an award if they would have otherwise been allowable.

Conference Registration Fees:

Non-refundable registration fees for conferences, symposiums, or seminars that have been canceled due to COVID19 may be charged to the award if they would have otherwise been allowable (e.g., necessary to accomplish program objectives).

Federal Agency-Supported Meetings and Conferences:

Scientific meetings, conferences, and workshops supported by federal funding may be delayed or canceled due to COVID-19. Non-refundable costs associated with federal supported meetings and conferences affected by COVID-19 are allowable and may be requested as an administrative supplement to the appropriate funding agency. Recipients should contact their assigned grants management specialist and program official to provide documentation demonstrating the effect of COVID-19. The funding agency will work with the recipient to address the impact on the grant.

Please be mindful of the following for any costs charged to a sponsored award during the COVID-19 crisis:

· Recipients should not assume supplemental funding will be available should the costs incurred result in a shortage of funds to eventually carry out the project.

· Recipients must maintain appropriate records and cost documentation to substantiate the charge for any cancellation or other fees related to interruption of operations or services. Documentation should notate that the expense was incurred as a result of the COVID-19 crisis.