The memorandum issued by the Office of Management and Budget (OMB) on March 9, 2020, outlines a series of temporary administrative relief measures for recipients and applicants of federal financial assistance directly impacted by the COVID-19 emergency. Recognizing the challenges posed by the pandemic, the OMB authorizes federal agencies to exercise flexibility and grant certain exceptions under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) for support of essential research and services. These measures are limited to the duration of the Public Health Emergency declared by the Department of Health and Human Services and are intended to ensure continued effectiveness in emergency response activities while maintaining accountability for federal funds.
The provisions allow for relaxed requirements regarding System for Award Management (SAM) registration, expedited publication of emergency funding opportunities, authorizing necessary pre-award costs dating from January 20, 2020, and no-cost extensions on expiring awards. Additional flexibilities include accepting abbreviated continuation requests, permitting the ongoing expenditure of award funds for salaries and project activities under unusual circumstances, authorizing waivers of certain prior approvals and procurement requirements, and allowing extensions for financial, performance, and audit reporting. These exceptions are designed to alleviate immediate administrative burdens for federal award recipients while upholding the underlying principles of stewardship and compliance, and agencies retain discretion to adopt and, if needed, further extend these flexibilities based on evolving circumstances during the public health crisis.
