These FAQs are for federal and non-federal grants. Some federal agencies are not adopting flexibilities allowed by OMB M-20-17 for specific award mechanisms, such as contracts or fixed price agreements. Please see the sponsor guidance page for agency-specific guidance.
Transactions that relate to COVID-19 specific policies should be carefully and fully documented. Departments and institutes must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 - Financial management and 2 CFR § 200.333 - Retention requirement of records. All supporting justifications must be retained according to the university record retention policies.
Communications with federal awarding agencies should be coordinated with OCG, CCO or the department/institute’s central research office.
If you have questions about a category of costs not covered in the FAQs below, or if you have questions related to expenditure allowability, please submit questions to CCOCovid-19@colorado.edu.
Office of Management & Budget (OMB) Related Questions
The OMB guidance sets the stage for temporary administrative relief to recipients and applicants of federal financial assistance (grants and cooperative agreements), during the Novel Coronavirus (COVID-19). The guidance is included in OMB Memorandums M-20-11 (March 9, 2020) and M-20-17 (March 19, 2020). The M-20-17 is an extension of M-20-11 and covers 13 topical areas applicable to grants administration.
These flexibilities are in accordance with 2 CFR 200.102 of the Uniform Guidance (“exceptions … permitted only in unusual circumstances”) and OMB will reassess the exceptions 90 days from March 19, 2020 (i.e., June 17th).
The guidance is applicable to federal financial assistance, but it is not applicable to contracts. OMB guidance on contracts is included in M-20-18, though does not contain the same flexibilities as it does for grants and cooperative agreements. At this point, we recommend each contract be approached on a case-by-case basis with the applicable contracting officer.
Allowability of salaries and other project activities (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405)
Awarding agencies may allow recipients to continue to charge salaries and benefits to currently active federal awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-federal.
Awarding agencies may allow other costs to be charged to federal awards necessary to resume activities supported by the award, consistent with applicable federal cost principles and the benefit to the project. Awarding agencies may also 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 progress reports and other communications with the grantee. Awarding agencies must require recipients to maintain appropriate records and cost documentation as required by 2 CFR § 200.302 - Financial management and 2 CFR § 200.333 - Retention requirement of records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services.
Allowability of costs not normally chargeable to awards (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405)
Awarding agencies may allow 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, 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. Awarding agencies may allow recipients to charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant. Awarding agencies must advise recipients that they should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel.
Awarding agencies must require recipients to maintain appropriate records and cost documentation as required by 2 CFR § 200.302 - Financial management and 2 CFR § 200.333 - Retention requirement of records, to substantiate the charging of any cancellation or other fees related to the interruption of operations or services. As appropriate, awarding agencies may list additional guidance on specific types of costs on their websites and/or provide a point of contact for an agency program official.
Compensation Related Questions
No, personnel are not allowed to use grant, contract or gift funds to make up for the 5% pay decrease.
CU provided administrative leave/idle time compensation through May 31, 2020. As of June 1, 2020, employees can no longer be compensated with idle or admin time if unable to work on their sponsored projects due to COVID-19. If such charges should occur, they must be moved from the award to a non-sponsored funding source.
If departments or institutes have employees who are impacted by the end of administrative leave/idle time compensation because they are still unable to work remotely for all or part of their role, department leadership needs to reach out to Employee Relations in Human Resources as soon as possible to discuss options and the way forward for those employees. Find your department contact on HR's Employee Relations page.
Background: The Office of Management and Budget (OMB) has authorized agencies to allow certain flexibilities, but agencies must explicitly allow recipients to exercise such flexibilities. The flexibilities include the ability to continue charging salaries consistent with institutional policy regarding paying salaries under unexpected or extraordinary circumstances from all funding sources, both federal and non-federal. Not all agencies may grant such authority, and there may be non-federal sponsors that do not offer similar flexibility. For information on agencies that have released guidance in accordance with OMB Memo M-20-17, please see COGR Matrix of Agency Terms. Regardless of the OMB guidance, we must comply with institutional policies, including the cessation of CU Boulder COVID-19 administrative leave/idle time compensation after May 31, 2020.
Please see the CU Department of Human Resources guidance webpage.
No. While it may be allowable to leave salary charges on funding sources in place at the time of the emergency declaration, it is not allowable to move salaries to an award if the individual is not working on that project.
Summer salary is not guaranteed compensation. Summer salary can be requested for work being performed remotely that benefits a sponsored project. If work cannot be performed, salary cannot be requested.
Travel Related Questions
The charge can remain on the originally charged sponsored award if the travel was related to the period of March 19-June 16.
Airfare credits should be used for the award on which the expense was originally incurred. However, we recognize that in some cases, the original traveler may not be able to use that ticket. In that situation, any of the following are acceptable alternatives:
Regardless of the funding organization, the individual’s first priority should be to work with the airline/hotel, as many are waiving change fees or offering full refunds for trips that you wish to change. Federal agencies have been granted the authority by the Office of Management and Budget to exercise certain flexibilities for grants and cooperative agreements. These include the ability to charge costs related to canceled travel. For further information about agencies that have provided guidance on these types of costs, see COGR Matrix of Agency Terms.
Many federal sponsors have released guidance allowing projects to charge cancellation fees from conferences and travel to grants. This includes NIH, NSF and DOD. Please refer to the COGR Matrix of Agency Terms for guidance related to your sponsor. Departments and institutes should take care to maintain documentation of the original charges and fees accrued due to cancellations.
(Last updated April 30, 2020)
Possibly, but not necessarily. The Office of Management and Budget has advised that recipients should not assume that additional funds will be available. Researchers may be able to request supplemental funding, but there is no guarantee that such funds will be awarded. We expect that federal agencies will recognize the difficulties inherent in this situation and work with institutions to facilitate the conduct of the project.
Generally, no it is not allowable, although we are still waiting for federal guidance. It should be noted, however, that traveler’s insurance may be prudent, but should be charged to institutional (but not sponsored projects) until we get additional federal guidance.
If a traveler has charged an airline ticket or other travel costs to a sponsored project, and then the trip is later canceled, the refund must accrue to the sponsored project.
Other Award Management Related Questions
Principal investigators should monitor their awards during the period of performance to assess financial capacity in order to determine whether additional time, money or a reduction of scope is necessary. Institutions may consider requesting administrative supplements in these cases in accordance with the agency’s guidelines but need to realize that there is no guarantee that funds will be available.
Work stoppages or delays to privately funded agreements and associated charges should be handled on a case-by-case basis. Principal investigators should consult with department/institute leadership and the Office of Contracts and Grants (OCG) to understand the nature of the relationship with the sponsor and review terms and conditions of the agreement (e.g., whether the notice had been given properly, termination clauses, force majeure terms) so institutions can weigh their options when determining how best to proceed. In many cases, the sponsor’s action will be fully consistent with the terms of the agreement, and there will be little the institution can do but comply. If the PI/institution has a good relationship with the sponsor, a conversation to consider other options may be worthwhile (remembering that agreements are with the institution and not the principal investigator). In the case where the sponsor’s action is not consistent with the terms of the agreement, the institution could choose to challenge the action, but should consider whether it will be worth it, given the level of effort such a challenge will take, along with the likely damage to the relationship.
Yes. We will continue to issue subawards as they are critical to the success of many sponsored projects. PIs should use their best judgement in determining the amount of subawards and the period of performance as the impact of the pandemic my limit the ability of subrecipients to perform all proposed activities.
The institution, as the prime recipient, is expected to continue to fulfill the aims of the project as proposed, unless extenuating circumstances warrant otherwise. Accordingly, most institutions continue to issue subawards if they are able to continue their research and work can still be performed by the subawardee. If an institution receives a stop work order, sponsored programs staff should review the terms of the prime award to determine the necessary steps for its subrecipients. Importantly, costs incurred after the receipt of a stop-work order would be at the financial risk of the awardee.
Yes. Any flexibilities related to the COVID-19 pandemic from our sponsors are flowed down to subrecipients. Invoices from subrecipients reflect costs incurred according to their institutional policies. The costs, therefore, are allowable on the sponsored award.
Yes. Supplies required to continue research operations are considered essential purchases. In purchasing these items, PIs should use their best judgement in determining the quantity needed and the frequency of purchasing as the impact of the pandemic may limit the ability to use the items as originally purchased.
OMB Memo M-20-20 authorizes federal agencies to allow recipients to donate personal protective equipment and other resources to support COVID-19 emergency response activities. In general, please check sponsor guidance related to the award on which the items were originally purchased. Please be aware that sponsors may make a distinction between transfers of materials between CU units and donations to external organizations (e.g., hospitals, clinics, non-profits, etc.).
The National Institutes of Health has indicated that this may be done without needing to seek NIH prior approval. See the NIH FAQ under Costs/Prior Approvals. The National Science Foundation, however, has requested that grantees contact their NSF program officers prior to taking such action. See the NSF implementation of M-20-20. Other agencies’ guidance may not yet be available. In all cases, whether the materials are considered shared or donated, please document and track the supplies.
For sponsored projects, outfitting a home workstation is generally an unallowable cost. The classification of direct cost versus indirect cost remains the same. Direct costs are clearly identified with a project’s activities and objectives. Indirect costs are not directly related to a specific sponsored project and are incurred for common or joint objectives. Indirect costs typically include office supplies or furniture and should be charged to non-sponsored funding.
The new COVID-19 data elements were created to identify COVID-19 activity for various reporting requirements including those from CU System Administration, FEMA, and the Coronavirus Aid, Relief, and Economic Security (CARES) Act, as well as for internal information.
CCO Research Financial Services (RFS) is planning to continue to process and submit all invoices and financial reports. Department and institute research administrators will continue to be contacted by CCO/RFS as part of the normal processes associated with these submissions.