Please see very important information below about documenting COVID-related expenses on sponsored fund sources.
From: UVA Office of Sponsored Programs <firstname.lastname@example.org>
Sent: Thursday, June 25, 2020 5:14 PM
To: Armstrong, Lauren B (Dean’s Office)*HS <LPB4C@hscmail.mcc.virginia.edu>
Subject: OSP | June 25, 2020 | Communication re OMB 20-26 Documentation and Requirements
I am writing today to provide an update on the administrative relief flexibilities provided by the U.S. Office of Management and Budget (OMB) in response to COVID-19 and our resultant obligations to document actions taken under such flexibilities. Based on the OMB Guidance, the individual federal agencies issue their guidance through agency-wide memorandums, dear colleague letters, FAQs, etc. OSP will continue to share the agencies’ guidance with you as soon as they are issued.
Update on OMB Flexibilities
As you will recall, on March 19, 2020 OMB issued Memorandum 20-17 that granted considerable administrative flexibilities to federal grant making agencies. These flexibilities included the ability to charge idle time to federal grants, the ability to charge costs not normally allowable on federal grants, waiver of prior approval requirements, extension of reporting deadlines and other changes. Federal grant making agencies were not required to adopt these flexibilities but most did so. All of the flexibilities in Memorandum 20-17 expired on June 16, 2020.
On June 18, OMB issued Memorandum 20-26, which extended, through September 30, 2020, the flexibilities of charging certain costs to federal grants:
- Idle Time (project team time in which no work is being done); and
- Costs to Resume Activities Supported by the Award.
As before, the charging of idle time is permitted only to the extent that it is consistent with UVA’s policies of paying salaries from all funding sources, federal and non-federal. A new requirement is that UVA must first “exhaust other available funding sources to sustain its workforce and implement necessary steps to save overall operational costs… during this pandemic period in order to preserve Federal funds for the ramp-up effort.”
This means we must first look to internal sources to pay for idle time on grants. Further, we must document our efforts to exhaust other funding sources and reduce overall operations costs to support charging idle time to any grant.
With the exception of flexibilities related to our single audit submission, no other flexibilities granted in OMB Memorandum 20-17 were extended.
OMB and federal grant making agencies require UVA to document the exceptional costs incurred under the flexibilities granted due to COVID-19. For example, we must be able to identify and justify the following charges:
- Idle effort
- Effort redirected to COVID-19 emergency response activities
- Costs to replace materials redirected to COVID-19 emergency response activities
- Research Ramp Down Costs
- Research Ramp Up Costs
- Costs Associated with Canceled Activities and Travel
Federal officials have stated that such costs will be scrutinized in future federal reviews and audits. Documentation of such costs also will be needed to justify supplemental funding requests to sponsors as well as seeking other potential sources of support for restarting research. It is the responsibility of Principal Investigators and their administrators to ensure such costs are identified and documented.
To help with this objective, UVA is working with Microsoft to adopt an application that will enable Principal Investigators and their administrators to identify a percentage of loss (idle time) and redirected effort for personnel costs. We anticipate making this available to the research community in coming days. OSP will be using the data collected from the MS app to identify the research projects in the financial system to isolate costs associated with COVID-19 disruptions.
Finally, I want to emphasize that open communication is an important component of meeting these requirements. It is expected that Principal Investigators are already communicating with their program officials on COVID-19 disruptions and are including information about such disruptions in their progress reports. This would include information about redirecting effort and materials to support COVID-19 emergency response activities. We strongly encourage research teams to reach out to their unit research administrators and OSP for additional guidance.
As research restarts across the University, OSP and our colleagues across Grounds will continue to help our faculty navigate complex administrative obligations created by COVID-19. I thank you for your attention to these critical issues.
Stewart P. Craig
Executive Director, Office of Sponsored Programs
Office of the Vice President for Research