This document, produced by the Council on Governmental Relations (COGR) as of May 28, 2020, provides an extensive series of frequently asked questions (FAQs) concerning costing and financial compliance for institutions receiving federal grants and cooperative agreements during the COVID-19 pandemic. Central to the discussion are the Office of Management and Budget (OMB) memoranda, particularly M-20-11 and its extension M-20-17, which outline temporary administrative flexibilities for federal financial assistance in response to the national emergency. The document clarifies that while agencies are encouraged, they are not required, to implement these flexibilities, which include guidance on allowability of salaries and project costs, extension of deadlines, and permissions for charging normally unallowable costs such as cancellations and disruptions directly attributed to the public health crisis.
The FAQs address practical concerns for research and financial administrators, such as maintaining consistency in cost treatment between federal and institutional funds, preserving comprehensive documentation, and addressing challenges with payroll, fringe benefits, indirect cost rates (F&A), and service center rates given pandemic-related financial disruptions. The importance of aligning institutional policies with federal guidance, particularly in treating COVID-19-related costs and managing staff compensation, is emphasized throughout. The document also highlights emerging issues—including the handling of ramp-down and ramp-up costs, financial reporting, equipment donations, and summer salary considerations—and recommends continued vigilance, adaptability in policy development, and proactive communication with agencies, auditors, and internal stakeholders. COGR underlines the evolving nature of guidance and the necessity for institutions to document decision-making processes thoroughly, especially in anticipation of audits and potential future reimbursements or relief measures.
