Research Ramp-Up-Sponsored Award FAQs
As of June 17, 2020, the flexibilities that were issued by the Office of Management and Budget (OMB) on March 19, 2020 (Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations) expired. On June 18, 2020, OMB issued a memorandum (Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations) extending 2 of the flexibilities that were in the original memorandum, including the allowability of charging salaries and benefits to active Federal awards consistent with the recipient’s policy of paying salaries from all funding sources. Based on additional information and a new legal interpretation of the OMB memo, salaries for individuals who are neither productive nor doing work that directly benefits the project are not allowed to be charged to federal awards after June 16, 2020.
Sponsored Award FAQs Current as of June 17, 2020
Only PPE necessary to conduct the sponsored research can be charged to a grant. In order to charge PPE to a grant, the cost must be appropriately allocated to the benefitting sponsored awards.
The purchase of PPE (masks, gloves, clothing coverings, footwear coverings, etc.) unrelated to the conduct of research but instead in order to return to the lab to comply with University safety requirements, is considered a general use purchase and cannot be charged directly to a grant(s) benefitting sponsored awards.
The purchase of sanitizing supplies necessary to conduct the sponsored research can be charged to the grant(s). In order to charge sanitizing supplies to multiple grants, the cost must be appropriately allocated to the benefitting sponsored awards.
The purchase of sanitizing supplies unrelated to the conduct of the research but instead is purchased for the sole purpose of complying with University safety requirements, is considered a general use purchase and cannot be charged directly to sponsored awards.
OMB extended the flexibility to allow charging salaries and benefits to active Federal awards consistent with the recipient’s policy of paying salaries from all funding sources.
Unfortunately, OMB’s extension of the flexibility included more restrictive language, and based upon a new legal interpretation, salaries for individuals who are neither productive nor doing work that directly benefits the project are not allowed to be charged to federal awards after June 16, 2020.
Yes, stipend payments may continue to be charged to NIH NRSA grants affected by COVID-19. Recipients should notify the Grants Management Specialist named in the notice of award and provide documentation demonstrating the effect of COVID-19, and how long the institution will be affected.
For T32/35, K awards and other training grants that support trainees, are these salary payments still allowable even if the individuals are unable to participate in the program due to the COVID-19 outbreak at Yale?
OMB’s more restrictive language does not allow for fellow and trainee stipends to continue to be paid from the project if they are unable to be productive in the training program in which the stipend is charged after June 16, 2020. If fellows and trainees were reassigned during the COVID-19 crisis, they must either resume their training activities after June 16, 2020 or their stipend costing allocation must be updated to reflect their current activities.
Please contact your grant manager who will assist you in seeking sponsor prior approval. All requests for prior approval must be reviewed and approved by OSP.
Depending on the nature of the work, the candidate may be able to work remotely. Please contact your HRG to discuss this situation.
For post-docs that are required to work on their originally approved work remotely from a foreign country due to COVID-19 travel restrictions, where no grant funds are going to a foreign entity, NIH has determined that this scenario does not constitute the performance of a significant scientific element or segment of the project outside the US, as outlined in the NIH Grants Policy Statement definition of a foreign component. Your HRG should be notified of these situations.
The answer to this question is complicated.
The ability to charge cancellation fees associated with project specific travel were also included in the expired OMB flexibilities. Any cancellation fees incurred on or after June 17 will no longer be able to be charged to the sponsored project. Please note that university travel restrictions are still in place.
Because each situation is unique, please submit all travel related questions to email@example.com.
If the original scope of work did not include this line of research, it would be considered a change in scope and would require the prior approval of the sponsor. Please contact your department business office (DBO) in order to submit a prior approval request to your Office of Sponsored Projects’ (OSP) award manager. OSP will submit the request to the sponsor for consideration.
NIH understands the potential effects of COVID-19 on the progress of NIH supported research. PIs must report any effects on the NIH funded research in their next RPPR submission. The funding IC will consider the effects that are reported by the recipient when reviewing and approving the RPPR. NIH remains committed to working with its applicants and recipients during this public health emergency. In addition, NIH recognizes that there may be delays in submission of RPPRs and other reports. See NOT-OD-20-086 for details on late submission.
Proposal applications and RPPR reports will be due on the normal established deadline schedule unless a specific exception has been granted by the agency.
Please contact Lisa Mosley, Executive Director, Office of Sponsored Projects at firstname.lastname@example.org; 203-785-3680.
FAQS Expired as of June 17, 2020
If applying to the National Science Foundation (NSF), requests for an extension are being reviewed by the NSF on a case by case basis. Please discuss the situation with your assigned Office of Sponsored Projects (OSP) (through your departmental administrator/FRMS) proposal manager. It is recommended that you discuss the situation with the cognizant Program Officer prior to submitting a request for a proposal deadline extension.
If applying to the National Institutes of Health (NIH) the NIH has advised that all grant applications submitted late for due dates between March 9, 2020, and May 1, 2020, will be accepted through May 1, 2020.
This notice applies to all relevant funding opportunity announcements, including those that indicate no late applications will be accepted. Institutions need not request advance permission to submit late due to this declared emergency and a cover letter providing a justification is not required.
Disclaimer: This notice pertains to applications reviewed by CSR and does not supersede the IC’s discretion nor authorities to make these decisions on case by case basis. Some Institute/Center (IC)-reviewed FOAs with due dates during this time may be able to accept applications beyond the May 1, 2020 deadline. However, applicants must contact the IC first, to confirm that a later deadline is possible.
NIH anticipates, but cannot guarantee, that all late applications submitted by that date will be reviewed in the council round to which they were submitted (e.g. August or October 2020). As much as NIH would like to extend flexibility further, this rapidly evolving situation also creates multiple challenges for conducting review, and the timeline for getting review outcomes to councils (so that funding can occur) can only be delayed so long. Therefore, applicants should assume that late applications submitted after May 1 may not be reviewed until meetings for the January 2021 council round (e.g., October-November 2020).
Department of Energy (DOE) will allow for submission of no more than 14 days after the original due date. Please discuss the situation with your assigned Office of Sponsored Projects (OSP) (through your departmental administrator/FRMS) proposal manager to facilitate the notification of the DOE Program Manager identified in the funding announcement.
Department of Defense (DOD) will consider late proposal submissions on a case by case basis. Please discuss the situation with your assigned Office of Sponsored Projects (OSP) (through your departmental administrator/FRMS) proposal manager to facilitate the notification of the DOD Program Officer and Grants Manager identified in the funding announcement.
No. However, Federal granting agencies including the NSF, NIH and DOE provide Yale with the ability to grant itself an initial no-cost extension (up to 12 months). If your project requires a no-cost extension, please work with your department business office (DBO) in order to submit a request to your Office of Sponsored Projects award manager. Once approved by OSP, OSP will notify the federal sponsor of the extension.
DOD requires prior approval for all no-cost extensions. If your project requires a no-cost extension, please work with your department business office (DBO) in order to submit a request to your Office of Sponsored Projects award manager. OSP will submit the request to DOD for consideration.
For NIH awards, NIH has advised grantees that late reports will be accepted. However, issuance of the next year’s funding increment will be delayed until the report has been submitted and accepted. Please work with your assigned OSP award manager and/or OSP grant accountant to notify the award’s Grants Management Specialist and Program Officer.
NSF has extended the due date of all annual progress reports and final project reports due between March 1 and April 30, 2020 by 30 days. NSF cannot make any new award or supplement any existing award, if the PI or Co-PIs has an overdue annual project report; therefore it is vital that annual reports are submitted by the revised due date.
DOE has requested reports be submitted as soon as practical, however, late reports may cause unavoidable delays in continuation funding.
DOD has advised they will allow submission of financial, performance and other reports on currently-active award accounts up to three months beyond the normal due date. For any other deliverables related to research awards, please contact the DOD grants manager and/or program manager for award specific guidance.
Yes. Yale NIH awards not under the Streamlined Non-competing Application Process (SNAP) may carry forward unobligated balances on active grants for immediate efforts to support activities related to or affected by COVID-19 as long as the charges are allowable costs and are within the scope of the original award.
In order for NIH to track the use of this flexibility and ensure that approval is noted prior to the submission and review of Federal Financial Reports (FFRs), recipients must contact the funding IC for approval.
In addition, affected recipients that have active non-SNAP grant projects may extend the final budget period of the approved project period on active grants one time for a period of up to 12 months without requesting prior approval, by notifying the assigned grants management specialist.
Charging salaries and benefits to grants that are active as of March 17, 2020 even when no work is being performed is allowable under the current circumstances. For employees whose work cannot be performed at home, it should be considered whether they can be reassigned to duties that can be performed at home or relieve others who are working on campus. If work can be performed on a different sponsored project, salaries should be charged as appropriate.
Current Yale guidance is that all employees (except those performing critical functions) are expected to work from home. If employees are working from home, they should be paid as they normally are, regardless of funding source. For employees whose work cannot be performed at home, it should be considered whether they can be reassigned to duties that can be performed at home or relieve others who are working on campus. If there is no reasonable alternative, employees should simply stay home and will be paid their regular pay between now and May 31, 2020. We expect additional guidance to be forthcoming from Yale on this ever-evolving situation.
For new awards with a start date after March 17, employees who are unable to perform work directly benefitting the project cannot have their salaries and benefits charged to that project.
Charging summer salary to sponsored projects is only appropriate if work benefiting the project can be done remotely. Please consider if travel restrictions or restricted access to campus may limit your ability to do such work.
The NIH has advised that Institutions affected by COVID-19 may continue to provide stipend payments to fellows and trainees who may be unable to work as a result of or related to COVID-19. Yale should notify the assigned grants management official, and provide documentation demonstrating the effect of COVID-19 on Yale, and how long the Yale will be affected.
Yes, T32 Trainees may be re-assigned to clinical duties and their salaries may continue to be charged to their grants.
The answer to this question is complicated.
The NIH states that non-refundable costs associated with grant-related travel that has been cancelled due to COVID-19 related complications may be charged to the NIH award if the costs would have otherwise been allowable. See NIH GPS 7.9.1 for detailed information on the allowability of travel expenses and the Yale travel policy.
If credit/vouchers have been granted for any of the travel expenses affected by the COVID-19 situation, you are required to use the credit/vouchers for future travel related to the project in which it was charged. You may not request additional funding from the sponsor to support travel if it is rescheduled in the future. If the credit/vouchers are not used for travel related to the original project, the costs should be reimbursed to the original project. Documentation should be kept to support the canceled travel and will be required if the credit/voucher will be used to support travel on a different sponsored project.
Institutions must document that costs charged to a grant are non-refundable and maintain documentation, in accordance with record retention requirements, and make them available to the federal agency upon request.
Because each situation is unique, please submit all travel related questions to email@example.com.
While the expense may be an allowable charge to the project, researchers are strongly encouraged to follow Yale’s guidance on restricted travel and social distancing. Additional information can be found on the Yale COVID-19 website, Limiting international and domestic travel.
During this time, Yale is discouraging visitors from coming to campus. Additional information is available by clicking on: Campus visitors.
If your scope of work did not originally include this work, this is considered a change in scope and will require prior approval from the sponsor. Please work with your department business office (DBO) in order to submit the request to your Office of Sponsored Projects award manager. OSP will submit the request to the sponsor for consideration.
National Institutes of Health (NIH):
- Update: NIH Late Application Policy Due to Public Health Emergency for United States for 2019 Novel Coronavirus (COVID-19)
- NIH FAQs: COVID-19 Flexibilities for Applicants and Recipients
- Coronavirus Disease 2019 (COVID-19): Information for NIH Applicants and Recipients
- NIH Late Application Policy due to Public Health Emergency for United States for 2019 Novel Coronavirus (COVID-19)
- General FAQs - Proposal Submission and Award Management Related to COVID-19
- Flexibilities Available to Applicants and Recipients of Federal Financial Assistance Affected by COVID-19