Policy Perspective

CGA FAQs COVID-19

The document is a set of Frequently Asked Questions (FAQs), dated May 8, 2020, addressing institutional concerns related to contracts and grants administration amidst the challenges posed by COVID-19. It provides guidance for universities and research institutions on managing work stoppages, delays, and charges to privately funded agreements, emphasizing the need for case-by-case assessment based on sponsor relationships and contractual terms, including force majeure and termination clauses. Institutions are encouraged to communicate directly with sponsors and consider both the feasibility and potential relational impacts of contesting sponsor actions that contravene contractual obligations.

The FAQs further address operational continuity in the issuance of subawards, emphasizing adherence to prime award terms and careful risk management in the face of stop work orders. There is guidance regarding the allowability of salary charges during periods of research inactivity, urging alignment with agency and institutional policies while keeping faculty informed about compliance protocols. Institutions are advised to monitor financial status of awards closely, consider administrative supplements where justified, and recognize agency-specific guidance—such as criteria from NIH and NSF—regarding supplemental funding during the pandemic. Additional questions highlight proper allocation of salaries when staff shift projects due to remote work feasibility and clarify that any continuation of salary payments must conform both to institutional emergency policies and relevant federal guidelines. Overall, the document advocates for proactive communication, adherence to both internal and external policies, and careful consideration of both legal and relational priorities in managing research agreements during COVID-19 disruptions.

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