COVID-19 Research Update

Center for Disease Control and Prevention (CDC)

• CDC’s Updated Considerations for Institutions of Higher Learning

The CDC emphasizes that “these considerations are meant to supplement—not replace—any state, local, territorial, or tribal health and safety laws, rules, and regulations with which IHEs must comply.

National Science Foundation

• FAQs Relating to NSF’s Implementation of OMB Memorandum M-20-26

Last month the Foundation issued guidance on NSF’s implementation of the Office of Management and Budget (OMB) Memorandum (M-20-26), entitled, 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. NSF remains committed to working with the Administration, other federal agencies, and the research community to effectively respond to the COVID-19 national emergency. This issuance implemented updated guidance authorized by OMB Memorandum M-20-26 for recipients affected by COVID-19. The guidance extends two of the short-term administrative relief from specific requirements contained in 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, without compromising accountability requirements. These extensions, that go beyond what OMB previously outlined in Memorandum M-20-17, specifically pertain to the allowability of salaries and other project activities and single audit submission. In order to support charges against NSF awards, recipients are reminded of their responsibility to maintain appropriate records and documentation to support the charges in accordance with institutional policies and procedures. OMB Memoranda M-20-17 and M-20-20 have been rescinded.

• NSF Guidance for Research Community
• Statement on Coronavirus Disease 2019 (COVID-19) — includes impact on NSF’s acceptance and review of proposals, impact on award oversight, impact on meetings funded via a grant from NSF, etc.

NSF Financial Management and Record Retention Requirements

During these challenging times, it is critical that you maintain appropriate cost documentation and records as required by 2 CFR 200.302, “Financial Management and 2 CFR 200.333, Retention Requirements for Records.”

• A special circumstance that we are facing is the appropriation of supplemental NSF funds under the Coronavirus Aid, Relief and Economic Security Act (CARES Act) providing our grantee community with resources to conduct COVID-19 related research. For grantees who have received COVID-19 supplements on existing awards, or who are exercising administrative flexibilities to complete their COVID research, we encourage that these recipients track these expenditures separately from those incurred under the normal scope of their award. The government-wide audit and oversight community, as well as NSF, are committed to sound stewardship of these funds. As such, maintaining strong internal controls over COVID-19 funding will provide a foundation for potential future reporting requirements for NSF and its research community.
• Awardees should continue to exercise strong internal controls and continue to practice effective financial stewardship under the pandemic environment. NSF will continue to process payments without interruption. Your assigned grant accountant can provide assistance as needed on any questions.
• Finally, NSF is distributing regular notices regarding cancelling appropriations on existing awards. Per federal appropriation law, the funds listed in these notices will no longer be available for drawdown after September 30, 2020. We strongly encourage financial managers and principal investigators to monitor these balances on their awards to ensure the funding is not lost at fiscal year-end. Awardees are cautioned against advancing remaining funds simply to expend remaining balances, and as always, excess funds drawn should be returned to NSF as soon as practicable.

Department of Energy and Office of Science

A list of all FOAs and DOE Laboratory Announcements may be found at https://science.osti.gov/grants/FOAs/Open, and https://science.osti.gov/grants/Lab-Announcements/Open, respectively.

• See letter from DOE and SC for COVID-19 FAQs.
• Non-Department-Funded Work (e.g., Strategic Partnership Project activities); guidance to National Laboratories, NNSA Plants, and other Contractors

National Institutes of Health

The NIH is deeply concerned for the health and safety of people involved in NIH research, and about the effects on the biomedical enterprise in the areas affected by the HHS declared public health emergency for COVID-19. Due to the potential exceptional impact, we want to assure our recipient community that NIH will be doing our part to help you continue your research. For NIH FAQs go to https://grants.nih.gov/faqs#/covid-19.htm.

Visit our COVID-19 page to see new and updated FAQs, including:

• During the pandemic, how may the IACUC expedite the three-year complete review of a currently approved protocol that is due to expire and still meet the PHS Policy requirements?
• May email responses from each IACUC member be used instead of digital or scanned signatures for the semiannual report to the Institutional Official?
• What flexibilities may IACUCS use to streamline approval of requests for an increase in previously approved animal numbers because of the COVID-19 pandemic?

Also, note that that many of the flexibilities provided in NOT-OD-20-086 have now expired. Recipients may rebudget funds to accommodate unanticipated costs without prior approval when rebudgeting does not constitute a change in scope and is not restricted by the terms and conditions of award (see NIH GPS 8.1).

• NIH Notice on Late Submissions
• General Frequently Asked Questions (FAQs) – Proposal Submission and Award Management Related to COVID-19
• NIH Late Application Policy Due to Public Health Emergency for United States for 2019 Novel Coronavirus (COVID-19)

National Institute of Allergy and Infectious Diseases (NIAID)

• Coronaviruses: Information for Researchers
• Multi-Pronged Response to the COVID-2019 Outbreak

National Aeronautics and Space Administration

• Assistant Administrator for Procurement Message on the Coronavirus

Department of Health and Human Services

• Letter to DHS Contractors Regarding COVID-19

Federal Bureau of Investigation

• Memo (5/13/2020) – People’s Republic of China (PRC) Targeting COVID-19 Research Organizations

Mississippi Arts Commission

MAC has developed a COVID-19 specific Grant Change Form (attached). Please, complete this form as soon as possible if your grant activity has been impacted by the coronavirus outbreak. Include any current plans to change or postpone grant activities as well as any proposal for alternative disbursement of your grant funds contingent on MAC approval. Submit the form to Arts Industry Director, Kristen Brandt at kbrandt@arts.ms.gov. If you are unable to submit via email, mail your form to 501 North West Street Suite 1101A, Jackson, MS 39201.