This document, released by the Council on Governmental Relations (COGR) as of May 1, 2020, provides a structured set of frequently asked questions (FAQs) addressing costing and financial compliance for institutions managing federal grants and cooperative agreements during the COVID-19 pandemic. The FAQs primarily interpret and offer guidance on the Office of Management and Budget (OMB) memoranda M-20-11, M-20-17, and related directives, which offer temporary administrative relief and flexibilities for grantees affected by operational disruptions. These flexibilities include allowance of salary and benefit continuation, costs associated with cancellations, and deviations from typical cost allowability under federal awards, provided that institutional policies are applied consistently and that robust documentation is maintained in accordance with 2 CFR 200 standards. The document underscores the importance of maintaining consistent treatment of costs across federal and non-federal funding sources, adhering to the consistency principle outlined in Uniform Guidance, and preserving comprehensive records justifying institutional responses and financial decisions during the crisis.
The FAQ further highlights the evolving nature of guidance, urging institutions to monitor agency-specific updates and to directly communicate with federal program officers or COGR when uncertainties arise. Attention is given to critical operational topics such as effort reporting, single audits, indirect cost rate negotiations, fringe benefit rate proposals, the handling of donations or repurposing of federally funded equipment, and the financial challenges facing service centers. The document also addresses practical concerns around property inventory requirements, application of administrative flexibilities for reporting and closeout, and potential eligibility for FEMA reimbursement. Throughout, COGR emphasizes a cautious yet pragmatic approach, advising institutions to rely on best judgement when explicit guidance is absent, and to meticulously document all actions and decisions related to COVID-19 disruptions for compliance and future audit purposes. Additional updates, particularly pertaining to summer operations and compensation matters, are anticipated in future releases.
