This document provides detailed guidance on the updated NIH procedures and flexibilities in response to the COVID-19 pandemic, especially as informed by OMB Memorandum M-20-26 and subsequent NIH policies as of August 2020. It outlines the expiration and limited extension of certain administrative flexibilities originally granted under prior OMB memoranda, highlighting the continued allowance—until specified dates—of salary charges and single audit reporting extensions for grant recipients impacted by the pandemic. Notification protocols require institutions to communicate the pandemic's impact on NIH-funded projects via the standard RPPR mechanism, rather than through blanket notifications, and offer guidance on handling delays in reporting, research disruptions, and closeout processes.
Further, the document addresses procedural adaptations for clinical trial reporting, animal research protocols, and IACUC activities, offering temporary flexibilities for inspections, program reviews, and protocol amendments, while emphasizing the maintenance of essential safeguards and documentation. The guidance clarifies policies on charging salaries and benefits—including for re-assigned personnel and trainees—and on payment of stipends under extraordinary circumstances, with institutional policies and documentation being critical for compliance. Additional topics covered include carryover of trainee funds, supplemental funding requests, allowability of telework-related costs, international trainee participation, and the handling of compliance issues. NIH’s responses reflect a case-by-case evaluation framework and encourage institutions to consult with NIH staff as pandemic-related impacts continue to evolve, while underscoring the importance of adherence to unaltered federal and NIH regulations and prudent stewardship of public funds.
