The document provides a detailed situational update on federal agency guidance and institutional responses related to the impacts of COVID-19 on the administration of federal awards, with a focus on funding, operational flexibilities, and compliance. Following the issuance of several Office of Management and Budget (OMB) memoranda, including M-20-17, federal agencies were instructed to offer temporary administrative and financial management flexibilities under the Uniform Guidance, allowing institutions to navigate disruptions caused by the pandemic. However, the degree and type of flexibilities permitted, such as salary charges for employees unable to work due to COVID-19 restrictions, have varied across agencies. For instance, initial USAMRAA guidance was more restrictive than NIH's policies, but this was later amended to align with institutional policies after OMB guidance. The Council on Governmental Relations (COGR) has actively advocated for consistent and broad adoption of OMB-permitted flexibilities and has developed resources, including a matrix summarizing major agency approaches and updated FAQs, to assist institutions during this evolving situation.
The document also addresses key issues arising from pandemic-related disruptions, such as handling cancelled travel costs, managing remote work and business continuity, ensuring compliance with institutional and federal policies, and maintaining documentation for future audits. It outlines procedures for allowable costs related to cancelled events, extended project timelines, and salary charges during employee quarantines or institutional closures, underscoring the importance of adhering to both agency-specific and institutional policies. The guidance stresses the necessity for clear records of institutional policies, ongoing communication with funding agencies, and thorough documentation of decisions and justifications. In addition, the document covers impacts on human subjects and animal research, supply purchases, tuition payments, and grant proposal submissions, emphasizing the need for institutions to remain informed through continuing updates and to consult sponsor-specific guidance as the public health emergency and regulatory responses continue to develop.
