Charging Grants and Contracts (Including Salaries) During COVID-19
Posted 4/6/2020
We are aware that there are many questions regarding salaries of graduate students, post-docs and junior faculty who depend on laboratory research during the shelter-in-place order. Although further information will be forthcoming, we anticipate considerable accommodation from the university and funding agencies. The following summarizes the information that we have been able to gather so far for federal and non-federal awards.
UCOP’s office of Research Policy Analysis and Coordination (RPAC) has compiled sponsor guidance information. They have also posted guidance related to leave for academic appointees.
Charging Federal Awards
UCOP Guidance
UCOP has posted guidance on charging grants and costs to Federal sponsored awards during COVID-19. The guidance states:
“At this time, campuses should continue to charge salaries, stipends, and benefits to currently active awards consistent with the UC policy of paying salaries from all funding sources, federal and non-federal. Likewise costs related to the cancellation of events, travel, or other authorized activities due to the COVID-19 crisis, may charge these costs to their award if they would have otherwise been allowable. Please ensure appropriate records and cost documentation are maintained to substantiate the charging of any cancellation or other fees related to interruption of operations or services.”
Federal Guidance
In March 2020, OMB issued Memoranda M-20-11 “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly impacted by the Novel Coronavirus (COVID-19),” and 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.” In M-20-17, the OMB addresses charging salary (section 6) and non-salary non-refundable costs (section 7) to awards.
Below is a table summarizing which agencies have adopted the guidance of OMB M-17-20 and allow salary and other non-refundable costs to be charged to awards (information compiled from the UCOP RPAC sponsor guidance website). This information is changing daily, so please check the UCOP RPAC website for updates.
| Federal Agency | Allows Salaries of Non-Working Researchers to be Charged to Award | Allows Non-Refundable Costs to be Charged to Award (travel, conference registration, etc.) |
| NIH
*adopted OMB M-20-17 guidance View guidance document and FAQ |
Yes. 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. | Yes. Non-refundable costs associated with grant-related travel that has been cancelled due to COVID-19 may be charged to the NIH award if they would have otherwise been allowable. |
| NSF
*adopted OMB M-20-17 guidance
|
Yes. Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active NSF awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. | Yes. Recipients who incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to the public health emergency, are authorized to charge these costs to their award |
| USDA NIFA
*adopted OMB M-20-17 guidance View source document |
Yes. Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active USDA NIFA awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. | Yes. If the costs were otherwise allowable costs prior to cancellation, and your organization took mitigation steps to reduce any financial loss of award funds, then NIFA will allow the associated costs. |
| Dept of Defense
*adopted OMB M-20-17 guidance
|
Yes. DOD will allow recipients to continue to charge salaries and benefits to currently active awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal. | Yes, DOD will allow nonrefundable travel expenses incurred for travel canceled due to COVID-19 to be charged to active awards. |
Non-Federal Awards
For California state awards, please contact your program officer for clarity.
PCORI released guidance with less flexibility on April 2, 2020.
“PCORI will only allow recipients to charge salaries and benefits to currently active awards for work performed to meet the objectives/needs of the project, regardless of the location where those duties are performed (i.e., work from home).”
For questions, please contact [email protected]
