COVID-19 Salary Guidance for Grants/Contracts - March 20, 2020
March 20, 2020
Given the current issues surrounding COVID-19, we wanted to provide a brief update in relation to the charging of salaries/fringe benefits to grants/contracts.
As the University remains operational, for all grants/contracts in which project-related activities continue without disruption, all applicable salaries/fringe benefits should continue to be charged accordingly.
As a reminder, if you are the principal investigator of a grant/contract and you anticipate that your deliverables will be delayed by offsite work or staff disruptions, please contact your program officer or technical point of contact immediately to let them know of your work plan adjustments and copy the Office of Sponsored Programs (email@example.com) on the communication. The appropriate OSP Contract Administrator will be made aware of the notice.
Currently, there remains uncertainty related to what federal agencies will be allowing in regard to the charging of salaries/fringe benefits to sponsored programs for which a disruption causes effort to be curtailed, however the Office of Management and Budget has released OMB Memo M-20-11 (“Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus”) and OMB Memo M-20-17 (“Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations”) with the intention of providing flexibility to federal agencies in their application of 2 CFR 200. Note that this is not direct guidance to recipients of federal financial assistance.
Currently, NIH is the only agency that has publicly announced their intent to incorporate this flexibility via NOT-OD-20-086:
Cost Related Flexibilities/Expenditure of Award Funds - Salaries:
NIH understands that many researchers may be unable to work as a result of or related to the effects of COVID-19. If a recipient organization’s policy allows for the charging of salaries and benefits during periods when no work is performed due to the effect of COVID-19, regardless of the funding source, including Federal and non-Federal, then such charges to NIH grant awards will be allowable.
Reminder: NIH awarding Institutes/Centers (ICs) may request documentation to confirm the requirements of institutional policies.
At this time, the Department of Defense will only allow recipients to charge salaries and benefits to currently active awards for work actually performed to meet the project activities, regardless of the location where those duties are performed (i.e., telework eligible). Some allowable activities may include -- e.g., data analysis, preparation of articles and papers based on the analysis of the research findings, monitoring subrecipients, care of research animals, direct charged administrative costs, etc.
If agency-specific guidance has not been issued salaries should be charged to unrestricted funds until further clarification is issued. If salary/wage transfers are appropriate at a later date, CGA will waive the 90-day transfer deadline, given the extraordinary circumstances.
A matrix is being developed to reflect agency guidance related to salaries as information is released. This document will be shared as more agencies provide their plan. In addition, sponsor information related to COVID-19 (deadline extensions, contact information, administrative guidance) is being shared via the OVPRED website (COVID -19 Information Received from Sponsors). For more information, visit the university’s COVID-19 information page and sign up for daily email updates.
James Weyhenmeyer, PhD
Vice President for Research and Economic Development