Contacting Sponsors About the Impact of COVID-19

Many sponsors have recently issued COVID-19 guidance  for PIs that need special accommodations for late proposals, delayed reports, project costs, and/or other project issues related to the impact of COVID-19. The following is a suggested introduction that can be used when communicating with sponsors that require a written justification for the requested accommodation due to the impact of COVID-19 (or the University’s response to COVID-19).This should be coordinated with OGCA.

My project (Insert Title/Award Number) has been affected in the following ways:  (Insert a description of the specific impact of COVID-19—or the University’s response to COVID-19—has had on your project and the accommodation you are requesting from the sponsor (e.g. late proposal, delayed report/s, cost flexibility, etc.)

Note on Applicability

These FAQs are for federal and non-federal grants. Some federal agencies are not adopting flexibilities allowed by OMB M-20-17 for specific award mechanisms, such as contracts or fixed price agreements.

5 Issues That Every Researcher Should Be Prepared to Address

1. OMB issued a memorandum providing federal agencies with additional flexibilities for grants to allow for COVID-19-related reimbursements, such as allowing administrative leave, other sick leave and vacation accruals to be charged against federal grants during the current COVID-19 crisis. Read the memorandum here. Variances to the OMB guidance will be regularly updated. 
2. Supplemental funding may be made available by agencies to cover some of the unexpected costs related to the COVID-19 emergency.  
3. All expenses related to COVID-19 should be tracked closely to facilitate the process of applying for supplements when they are made available. 
4. Grant budgets must be carefully managed, even with unanticipated expenses, to ensure that researchers do not overspend on existing grant budgets. It is not clear what portion of unanticipated expenses will be covered through supplements, nor do we anticipate other sources of funding (internal or external) for such expenses. 
5. PI’s are encouraged to contact agency program managers as soon as possible, by phone and in writing, to ensure they are fully aware of the challenges and likely costs to grants for which PIs will require supplemental funding.

While federal and private sponsors have been emphasizing flexibility around prior approval requirements and the allowability of costs on sponsored projects, you must still contact OGCA prior to:

• Submission of Late Progress Reports (when the progress report is submitted through SPA, such as NIH RPPRs)
• Submission of Final Closeout Requirements
• Requesting 1st and 2nd No Cost Extensions
• Carryover of NIH non-SNAP unobligated balances
• The subawarding or transferring out of any work
• The transfer of funds budgeted for  participant support costs to other categories of expense
• Change in PI (or co-PI in NSF awards)
• Disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project by the approved PI/PD.
• Any changes in scope.

Allowability of Costs Related to COVID-19

Can I still charge participant support costs to my award for conference or training events that have been cancelled?

This depends on the type of participant support.  Please see the following scenarios:

1. Participant travel allowances: These costs should be handled the same as other travel costs. When an emergency or natural disaster prevents travel and nonrefundable costs cannot be applied to future travel, sponsors allow these costs to be charged to sponsored awards. Cancellation and change fees can also generally be charged to sponsored awards but require confirmation from the sponsor. Costs that can be applied to future travel should be moved to a non-sponsored fund until they are utilized for travel.
2. Participant registration fees:Participant registration fees are usually refundable for cancelled events.  If not, please contact OGCA to have them confirm allow-ability to charge the project for any non-refundable portion or cancellation fee with the sponsor.
3. Participant stipends: This will depend on the nature of the event.
   1. If a short-term educational or research activity, conference, workshop, etc., has started, but is now postponed or cancelled, payments can be made to the participants for the completed portion. 
   2. In the case of a long-term educational experience, stipend payments are typically made along milestones or on a schedule.  Payments can be made to participants for completed portions.  For incomplete portions, or future involvement, please contact OGCA to have them confirm allow-ability with the sponsor.
   3. In a case where travel plans were made but cancelled prior to the participants engaging in the activity or program, follow the guidance for travel cancellations.  In these instances, stipends are likely not allowable.  Please reach out to OGCA for additional review and determinations.

Will a grant sponsor provide flexibility on prior approval requirements for administrative actions as a result of COVID-19 such as carryover of an unobligated balance?

• Yes, many sponsors have expressed that they will be flexible with prior approval requirements for administrative changes to a grant. For example, NIH stated on a call that prior approval will not be required for the carryover of an obligated balance. If you have a specific question about a change to your grant, please contact OGCA

Are federal agencies going to allow grant recipients to request supplemental funding because of the impact of COVID-19?

• As sponsors provide funding opportunities, OGCA can help faculty locate funding and answer any questions related to additional funding.
• We would use the standard agency process for requesting supplements and agencies should make decisions through their normal agency processes.

Will a grant sponsor provide flexibility on late reports due to COVID-19?

• NIH will allow recipients that are affected by COVID-19 to delay submission of financial, performance and other reports required by the terms and conditions of the grant award, provided proper notice about the reporting delay is given by the recipient to NIH. NIH will accept these late reports, but will delay issuing any continuing grant awards until the reports are received and accepted.

• NSF has automatically extended the due date for submission of all annual project reports due between March 1 and April 30, 2020, by 30 days. These project reports must continue to be submitted via Research.gov. PIs are reminded that NSF cannot make any new award or supplement any existing award, if the PI(s) or any co-PI(s) has an overdue annual project report; therefore, it is vital that annual reports are submitted by the revised due date.

• NSF has automatically extended the due date for submission of all final project reports and Project Outcomes Reports due between March 1 and April 30, 2020, by 30 days. These final reports must continue to be submitted via Research.gov. Recipients are reminded that NSF cannot make any new award or supplement any existing award if the PI or any co-PI(s)s has an overdue final report; therefore, it is vital that final reports be submitted by the revised due date.
• DOD will allow grantees to delay 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. 

If the agency program officer or grants officer is unavailable (or if the agency is closed) due to COVID-19, can grant personnel continue to work and charge salary to the project?

• In most cases, grantees should be able to continue work until their period of performance and funding is exhausted. If prior approvals are required, the grantee should continue to submit their request to the funding agency electronically. Contact OGCA for further information.

Will a sponsor provide an extension to my grant award if the planned activities are disrupted by COVID-19?

• Many sponsors allow for one-year grantee-approved no-cost extensions. If your sponsor does not provide for this pre-approval, please OGCA to determine how to make an extension request to the sponsor.

What do I do if I overspend on my grant and the sponsor is unable to/unwilling to/does not pre-approve) to provide supplemental funding?

• Please contact your agency program managers as soon as possible, by phone and in writing, to ensure they are fully aware of the challenges and likely costs to your grant for which you will require supplemental funding. If you agency program manager is supportive of a request for supplemental funding, please contact OGCA for the next steps

• Are travel costs, which have been cancelled due to COVID-19, allowable on sponsored funding?
  • Federal agencies are working internally on a number of proposal and award-related issues pertaining to COVID-19. We are waiting on further communication from our partners about these issues and will provide guidance as further information becomes available. In the meantime, please continue to follow all relevant policies and procedures and apply those practices consistently. Currently, per UA travel regulations, as long as the circumstances were outside of the traveler’s control, fees for changing/cancelling flights are payable/reimbursable by the University (e.g. meeting dates changed). If the original expense was allocable to a sponsored project, the subsequent fees for changing/cancelling travel would also be allocable to that project.

• Am I allowed to pay staff who may be quarantined on sponsored funding?
  • Federal agencies are working internally on a number of proposal and award-related issues pertaining to COVID-19. We are waiting on further communication from our partners about these issues and will provide guidance as further information becomes available. In the meantime, please continue to follow all relevant policies and procedures and apply those practices consistently. Currently, salary should be charged in a consistent manner. If an employee's salary is charged to a sponsored program, then their time spent in quarantine can also be charged to the sponsored program.

• Can I change trip cancellation insurance to my grant?
  • Trip cancellation insurance is typically unallowable on grants. However, we are monitoring any additional guidance the federal government may issue related to travel. If you need to travel in the coming months to conduct business for a sponsored project, and you want to purchase trip cancellation insurance, you may reach out to OGCA to request prior approval from the sponsor to charge this cost to the grant.

• I am a PI/researcher and I am required to work from home as a result of the coronavirus. Would I be able to change supplies related to telework (i.e. such as my laptop, printer, office supplies etc..) to my grant?
  • These types of expenses are considered administrative costs (indirect costs), and generally are not appropriate as a direct cost unless specifically approved by the sponsor. You may wish to talk with your Dean/Director/Supervisor about your needs in order to be set up to work from home.

• I am a PI working remotely from home during self-isolation. Can my effort still be charged to the grant?
  • In general, yes, provided you remain engaged in your project.  Current NIH and NSF prior approval requirements regarding disengagement and effort reductions remain in effect.

• I am planning to travel to a conference to present my research work supported by my grant, but the conference was cancelled due to precautions regarding COVID-19? May I still charge the travel related costs to the grant?
  • To date, there is no federal guidance relating to charges to awards for non-refundabletravel, conferences, and related expenses due to the coronavirus. Please continue to follow the University Travel Expense Policy and general cost principles described in the Uniform Guidance.  As information becomes available we will update accordingly.

NASA Grant Recipients 

Personal Protective Equipment (PPE) was purchased using grant funding. Can PPE be donated to local first responders?

Donating Personal Protective Equipment (PPE) purchased with NASA grant funding to first responders is allowed under grants directly related to the COVID-19 emergency response and grants not related to the COVID-19 response on a case-by-case basis. However, the recipient should not assume that additional funds are available should the costs of donating the equipment result in a shortage of funding or supplies at a later date. Additionally, before donating the PPE, recipients must first notify and obtain approval from their cognizant NASA program office. The recipient must also document and maintain records on all PPE donated to local first responders in response to the COVID-19 crisis. The prior approval request should be submitted through OGCA to NASA.

NIH guidance says, “Recipients that are not under Streamlined Non-competing Application Process (SNAP) have the discretion to carry forward unobligated balances on their 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.” What does NIH mean when they say “affected by” in this statement?

• This is interpreted to mean that even though a project may not be related to research specifically on COVID-19, if the COVID-19 pandemic has affected the research from progressing, then recipients not under SNAP may carryforward funds without prior approval. Our interpretation is that all UAF research transitioned to remote activities may be affected and can fall into this category. Do be aware that carryforward amounts are subject to annual appropriations.

Does NIH have any follow-up regarding the issue of whether graduate students and post-docs will be considered “foreign components” if they are working on grants outside of the U.S. because of travel restrictions resulting from the COVID public health emergency that have prevented them from coming to the U.S.?

• NIH stated that the answer to this question is “yes” and have posted a FAQ to this effect:NIH FAQ regarding "foreign components." NIH also discussed the issue of prior approval required for foreign components and stated that there may already be flexibilities in place and that it will discuss this matter further internally.

How does remote work arrangements during the COVID-19 pandemic impact new requests for summer/supplemental salary?

• Summer/supplemental pay is not guaranteed compensation. Summer/supplemental salary can be requested for work being performed remotely that benefits a sponsored project. If work cannot be performed, salary cannot be requested.

What steps can I take now that will help get my research projects and lab up and running and well-funded once the coronavirus crisis ends?

1. Keep track of and document expenses caused by the shutdown of your sponsored research. This would include any materials and supplies you may have generously donated to support the COVID-19 response effort. We have records from the forms you submitted, but if your lab completed the PPE inventory donation form as a part of a larger department donation, please try to estimate and track your individual contribution. It is also important to track costs of keeping your projects viable while in a suspended state. Some of the federal funding agencies have indicated a willingness to consider administrative supplements to existing awards when our research labs reopen.

1. Reach out and maintain communications with the program officers who oversee your awards. Decisions about administrative supplements will likely be made at the program level. They will appreciate hearing from you about the status of your current project. However, it is premature to make supplemental requests now. Wait until you know the full impact of the shutdown on your ability to complete your funded work. With respect to flexibilities on NIH grants, this blog and video from Mike Lauer is especially helpful in explaining NIH’s policies.

1. Keep submitting new proposals. The $2 trillion stimulus bill just passed by Congress includes major new funds across multiple agencies for research that addresses COVID-19 including NIH, NSF, DOD, DOE, NIST, and NEH. Many of these agencies will expedite decisions on these awards, most notably the RAPID program administered by NSF.

As for non-COVID-19 research, it may seem counterintuitive to seek funding for new projects while existing ones are idle, but OGCA urges you to do so. The federal funding agencies continue to encourage proposals in all areas of science. Deadlines have been extended for certain programs. OGCA will work with you to get proposals submitted.

Where can I get more information on sponsor-specific policies concerning disasters and emergencies?

• See NIH Extramural Response to Natural Disasters and Other Emergencies
• See NSF Responses to Natural Disasters

At what point do I need to contact the sponsor of my grant?

• When your research project results in:
• A technical or programmatic occurrence that the PI wants to alert the sponsor about*;
• The disengagement of the PI of 3 months or more to the research;
• A reduction of 25% or more in the time devoted to the project;
• A change in scope of work;
• A significant delay to complete the project on time; or
• A significant increase in costs to complete the project,

*Best practice would be to notify program officers for federal grants of substantive changes or interruptions to your protocol at your earliest convenience.   This will allow them to best represent the challenges grantees are facing to their respective agencies.

Please contact OGCA to help coordinate and communicate these impacts with program officers, managers, or sponsor personnel as required.

 If I have a grant, who should I contact if my project activities are impacted by COVID-19?

• As Principal Investigator (PI), you continue to be responsible for conducting your research in a safe and secure manner. UAF leadership is providing guidance and assistance to aid you as you make decisions regarding your research. Accordingly, if project activities are impacted, contact your immediate supervisor, unit leadership (Chair, Dean/Director, other), central offices (particularly OGCA, IRB, IACUC, EH&S, etc.), collaborators, or sponsors, as appropriate.

How will the pause in my research impact my grant?

• Generally, there should not be significant impact to your grant. All study-related activities that are not affected by a pause can continue as normal. Additionally, there should not be a significant disengagement of the PI or other senior key personnel from affected projects.

Personal protection equipment needed to perform the grant can be a direct charge. Supplies needed for cleaning should be covered by a non-grant account.

• We have been asked to track all COVID-19-related expenses. Please ensure that you keep careful track of these expenses.
• You may find more useful information through the Council on Governmental Relations (COGR) webpage "FAQs Regarding COVID-19's Impact on Federal Awards."

I was approached by a sponsor/foundation wishing to provide me with funds to conduct research relating to COVID-19. What should I do?

• Conducting any sponsored activities require multiple offices to review and negotiate the terms of the sponsored award and to assist you in obtaining required institutional approvals (e.g., IRB, IBC, etc.). You should immediately contact OGCA, who will then provide you information on next steps.

• What should I consider when assessing how COVID-19 might affect my research?

Now is a good time to consider how an outbreak of COVID-19 in Alaska might affect your research. Here is a list of questions to get you started.

Here are a few simple scenarios in order to consider these impacts:

• What would the impact be to your research and sponsored programs if you had to self-quarantine for two weeks?
• What would the impact be to your research and sponsored programs if more than one of your research staff had to self-quarantine for two weeks?
• What would the impact be to your research and sponsored programs if UAF advised all faculty and staff to work remotely?

Here are additional questions to help you assess how an outbreak may affect your research:

• Are there any studies involving participants, animals, ingredients, or experiments that would be adversely affected? If so, what plans should be put in place to allow for them to continue or allow for them to be stopped and later resumed in the least impactful way?
• What standing purchase orders or human resource issues might be impacted?
• Would data collection/analysis/storage be impacted and what costs would be associated with these impacts?
• What regulatory approvals will expire soon and might be impacted if they are not renewed? Can they be renewed early?
• Are there any collaborators that would need to be notified?
• What sponsor reports or deadlines are due during the next several months? Might you need to request a no-cost extension?
• What notice might you need to give sponsors or regulators if the research is going to be paused or significantly delayed beyond a couple of weeks?

Additional considerations for human subjects research:

• Is the location of the study remaining open and available for participants to be present? Has the location implemented any procedures to slow the spread of the coronavirus that will affect participation in your study or the ability of your study to proceed?
• Does your protocol require in-person participation or treatment? Can it be modified for remote participation?
• Does your protocol require in-person monitoring? Can it be modified for remote monitoring?
• Should your participants be screened for coronavirus as part of your inclusion/exclusion criteria?
• Would your data or results be affected if your participants had to self-quarantine or if they contracted coronavirus?

Additional considerations for environmental health and safety:

• Do you have a limited number of critical lab staff with unique knowledge? Are there others in your lab who can be cross-trained?
• Does your lab operate machines that use active cooling through liquid gasses, dry boxes, or inert boxes using gas blankets? What would happen if materials like liquid gasses, CO2, nitrogen, or dry ice become unavailable?
• How frequently are you saving or freezing samples of your cell cultures?
• Do you have long-term experiments that might benefit from more frequent preservation?
• Do you have the requisite local knowledge to do controlled shutdowns of complex machines or devices such as Nuclear Magnetic Resonance (NMRs) without on-site help from the company?
• Have you shared with EHS the locations and amounts of materials that are air, water, or otherwise unstable for observation in case of lab closure?

• I have a progress report due in the near term and my study is impacted by the pause. Do I need to include information related to the pause in my progress report?
  • Please discuss with OGCA about what information should be included.

• My study may be impacted by the pause which could lead to delays in completing my study by the end of the project period. What should I do?
• Most federal sponsors, including NIH, allow for a one-time no cost extension for 12 months at the end of the project. Please discuss your specific project with OGCA.