The document provides a comprehensive update on federal funding agency guidance and flexibilities in response to the disruptions caused by the COVID-19 pandemic. The Office of Management and Budget (OMB) has directed federal agencies to provide short-term administrative and financial relief, although implementation of these flexibilities varies by agency. Some agencies, such as the NIH, have permitted continued payment of salaries and coverage of certain non-refundable project costs related to cancelled conferences or travel, while others, like USAMRAA, have taken a more restrictive stance. The Council on Governmental Relations (COGR) is actively tracking these evolving policies, summarizing major issues for institutions, and recommending close adherence to both federal and institutional guidance, especially as agency responses may differ and change over time.
The document further elaborates on practical considerations and frequently asked questions regarding allowability of various costs under federal awards during COVID-19. Topics addressed include the management of cancelled travel and related credits, handling of remote work and research disruptions, implementation of emergency institutional policies, and documentation requirements for cost allowability. Additional guidance covers issues such as conference cancellations, salary charges during self-isolation or care responsibilities, purchase of COVID-19-related supplies, tuition payment continuity, and the conduct of research involving human subjects and animals. Institutions are encouraged to consult specific agency guidance, document decisions and impacts thoroughly, and communicate proactively with grant officers as they navigate administrative challenges and seek extensions or supplemental funding. The evolving nature of the situation underscores the need for institutions to maintain up-to-date policies, ensure transparency in financial management, and prioritize safety and compliance in their research operations.
