The document provides guidance for research institutions and recipients of federal awards navigating the impacts of COVID-19, interpreted under the Uniform Guidance (2 CFR 200). Institutions are advised to follow their own established emergency and disaster policies, particularly around business continuity, and to ensure these are clearly documented, versioned, and accessible. Key recommendations include thorough documentation of institutional policies and transactions, especially when incurring costs or making changes to federal awards during the public health emergency, as federal determination of cost allowability and reasonableness will consider both context and consistency.
The FAQs cover the allowability of COVID-19-related travel cancellation costs, management of travel credits, and the documentation required, especially in line with recent NIH guidance. Guidance also addresses remote work, continuity of salaries, approaches to project progress and delays, procurement of COVID-19-related materials, and adjustments to deadlines. Institutions are encouraged to maintain close communication with federal program officers and grant administrators as the situation evolves. The document stresses flexibility and proactive engagement, recommending detailed records for any deviations from standard practice. It cautions that federal agencies may interpret exceptions differently, especially between grants and contracts, and highlights the need for institutions to monitor evolving federal agency guidance. Overall, the document is positioned as interim advice from COGR and is not a substitute for formal federal or institutional directives.
