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OMB COVID-19 Memorandum Summary (M-20-17)

We wanted to provide an update on the recent memorandum from the Office of Management and Budget, which provides agencies with additional flexibilities for recipients affected by the loss of operational capacity and increased costs due to the COVID-19 crisis. Below are the details of the memorandum:

Administrative Relief Exceptions for COVID-19 Crisis

Flexibility with System Award Management (SAM) Registration

  • Allows federal awarding agencies to relax the requirement for active SAM registration at time of application to allow for quicker funding.
  • Current registrants with active registrations expiring before May 16, 2020 will be given a one-time 60-day extension.
  • If applicants encounter registration issues with SAM.gov and are unable to register, they may request a waiver to submit a paper application.

Flexibility with Application Deadlines

  • If the organization is unable to submit an application by the published Notice of Funding Opportunities (NOFO) you may request an extension by contacting HRSA’s Division of Grants Policy via email at DGPWaivers@hrsa.gov.
    • Email must include:
      • HRSA funding opportunity number
      • Organization name, address and telephone number
      • Organization’s DUNS number
      • Project Director’s name and telephone number

Waiver for NOFOs Publication

  • For NOFOs specifically related to COVID-19 response, awarding agencies have the option to post NOFOs on Grants.gov for less than 30 days.

No-cost Extension on Expiring Awards

  • Awarding 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 12 months.
  • Project-specific financial and performance reports will be due 90 days following the end date of the extension.
  • Extensions can be made through HRSA’s Electronic Handbooks.

Abbreviated Non-competitive Continuation (NCC) Requests

  • If an organization is unable to submit their NCC report by the posted due date they will need to contact their grants management specialist via email or phone.
  • All requests will be handled on a case by case basis, potential next steps may include deadline extension, one-time limited NCC report or other appropriate determinations.

Allowability of Salaries and Other Project Activities

  • HRSA recipients may continue to charge salaries and benefits to currently active awards consistent with their policy of paying salaries under unexpected or extraordinary circumstances from all funding sources.
  • If recipients don’t have such policies in place they should immediately develop and officially adopt the new policies.
  • Internal controls over time and effort documentation and reporting may be adjusted for staff unable to report to work, but recipients must document that they are following the organizational policy for charging salaries during unexpected and extraordinary circumstances.
  • Recipients must maintain appropriate records and cost documentation as required to substantiate the charges of any salaries and other project activities cost related to interruption of operations or services.

Allowability of Costs Not Normally Chargeable to Awards

  • HRSA recipients may charge full cost of cancellation fees when event, travel or other activities conducted under the grant are cancelled due to COVID-19.
  • Appropriate records and cost documentation must be maintained as required to substantiate the charging of any cancellation or other fees related to interruption of operations or services.

Prior Approval Requirement Waivers

  • HRSA may consider providing flexibility on a case by case basis.
  • If the impact of COVID-19 constitutes a temporary change in scope, the recipient must submit a request for prior approval in EHBs. After the public health emergency ends, the project scope will revert to the previously approved scope.
  • For Health Center Recipients, see specific change in scope flexibilities: PAL 2014-05: Updated Process for Requesting a Change in Scope to Add Temporary Sites in Response to Emergency Events

Exemption of Certain Procurement Requirements

  • HRSA has adopted flexibility to allow recipients to waive the procurement requirements regarding geographical preferences and contracting small and minority businesses, women’s business enterprises, and labor surplus area firms.
  • Recipients may solicit proposals from a single source if the item is only available from a single source or if the requirement will not permit a delay resulting from competitive solicitation.
  • Recipient should document any procurement decisions made in response to COVID-19. Flexibility is valid during the 90-day period from the Public Health Emergency Declaration.

Extension of Financial, Performance, and Other Reporting

  • Awarding agencies may allow grantees to delay submission of financial performance and other reports up to three months beyond the normal due date.
  • Extensions are requested through HRSA’s Electronic Handbook.
  • Contact your Grants Management Specialist with questions.

Extension of Closeout

  • Awarding agencies may permit grantees to delay submission of any pending financial, performance and other reports required by the terms of the award for the award for the closeout of expired projects, provided proper notice is given by the grantee to the agency.
  • Delay in submitting closeout reports may not exceed one year after the award expires
  • Extensions are requested through HRSA’s Electronic Handbook.

Extension of Single Audit Submission

  • HRSA recipients with awards issued in response to COVID-19 may delay their submission by up to 12 months.
  • HRSA recipients that do not have awards issued in response to COVID-19 but are affected by the loss of operational capacity due to COVID-19 may delay submission by a six-month extension.
  • Documentation of the reason for the delayed filing must be maintained.

Please visit our Coronavirus Resources & Information for additional guidance on related items. If you have further questions, please contact one of our team members.

References:

HRSA’s COVID-19 Grantee Frequently Asked Questions

OMB Memorandum March 19, 2020

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