Summary Administrative Relief Exceptions for COVID-19 Crisis
Federal awarding agencies are authorized to take the following actions, as they deem appropriate and to the extent permitted by law, with respect to the administrative provisions that apply to recipients and grantees affected by the COVID-19, for both recipients with COVID-19 related grants and other types of Federal grants.
Awarding agencies are required to maintain records on the level of particular exceptions provided to recipients. For items 6 and 7, awarding agencies must require recipients to maintain appropriate records and documentation to support the charges against the Federal awards.
1. Flexibility with SAM registration. (2 CFR § 200.205)
Awarding agencies can relax the requirement for active System for Award Management (SAM) registration at time of application in order to expeditiously issue funding. See M-20-17 for more information.
2. Flexibility with application deadlines. (2 CFR § 200.202)
Awarding agencies may provide flexibility with regard to the submission of competing applications in response to specific announcements, as well as unsolicited applications. As appropriate, agencies should list specific guidance on their websites and/or provide a point of contact for an agency program official. See M-20-17 for more information.
3. Waiver for Notice of Funding Opportunities (NOFOs) Publication. (2 CFR § 200.203)
Ability to publish emergency Notice of Funding Opportunities (NOFOs) for less than thirty (30) days on competitive grants and cooperative agreements. Documentation required by agency for tracking purposes. See M-20-17 for more information.
4. No-cost extensions on expiring awards. (2 CFR § 200.308)
Agencies may extend awards which were active as of March 31, 2020 and scheduled to expire prior or up to December 31, 2020, automatically at no-cost for a period of up to twelve (12) months. Required due dates of project-specific financial and performance reports 90 days following end date of extension. See M-20-17 for more information.
5. Abbreviated non-competitive continuation requests. (2 CFR § 200.308)
For continuation requests scheduled to come in from April 1, 2020 to December 31, 2020 agencies may accept a brief statement from recipients to verify they are in a position to 1) resume or restore project activities; and 2) accept a planned continuation award. See M-20-17 for more information.
6. Allowability of salaries and other project activities. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405)
Awarding agencies may allow recipients to continue to charge salaries and benefits to currently active Federal awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Awarding agencies may allow other costs to be charged to Federal awards necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. See M-20-17 for more information.
7. Allowability of Costs not Normally Chargeable to Awards. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405)
Awarding agencies may allow 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, to charge these costs to their award without regard to 2 CFR § 200.403, Factors affecting allowability of costs, 2 CFR § 200.404, Reasonable costs, and 2 CFR § 200.405, Allocable costs. See M-20-17 for more information.
8. Prior approval requirement waivers. (2 CPR § 200.407)
Awarding agencies are authorized to waive prior approval requirements as necessary to effectively address the response. See M-20-17 for more information.
9. Exemption of certain procurement requirements. (2 CPR§ 200.319(b), 2 CPR§ 200.321)
Awarding agencies may waive the procurement requirements contained in 2 CPR§ 200.319(b) regarding geographical preferences and 2 CPR§ 200.321 regarding contracting small and minority businesses, women's business enterprises, and labor surplus area firms. See M-20-17 for more information.
10. Extension of financial, performance, and other reporting. (2 CPR§ 200.327, 2 CPR§ 200.328)
Awarding agencies may allow grantees to delay submission of financial, performance and other reports up to three (3) months beyond the normal due date. See M-20-17 for more information.
11. Extension of currently approved indirect cost rates. (2 CPR§ 200.414 (c))
Awarding agencies may allow grantees to continue to use the currently approved indirect cost rates (i.e., predetermined, fixed, or provisional rates) to recover their indirect costs on Federal awards. See M-20-17 for more information.
12. Extension of closeout. (2 CPR§ 200.343)
Awarding agencies may allow the grantee to delay submission of any pending financial, performance and other reports required by the terms of the award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the grantee to the agency. This delay in submitting closeout reports may not exceed one year after the award expires. See M-20-17 for more information.
13. Extension of Single Audit submission. (2 CFR § 200.512)
Awarding agencies, in their capacity as cognizant or oversight agencies for audit, should allow recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of this memorandum that have fiscal year-ends through June 30, 2020, to delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501 -Audit Requirements, to six (6) months beyond the normal due date. See M-20-17 for more information.