VPR Issues Memorandum to Deans and Department Chairs Re: Effort Reporting During COVID-19 Pandemic
This memorandum and the accompanying Guideline G3-020 are provided to clarify the rules regarding payments from grants during the COVID-19 pandemic.
March 26, 2020
See COVID-19 Central @THEU for the status of all University of Utah operations and Research Community Updates on Coronavirus (COVID-19) for research specific operations and updates.
Last Update: 8/1/2022
Frequently Asked Questions
If you have additional questions that are not addressed in the following FAQ or resources, please email email@example.com.
Q: If employees must work from home will they still be able to get paid by grants? Specifically, if they usually are supervised, or punch in and out, etc., could we be called to task for suspending such oversight while allowing the work to continue?
A: If the University directs employees to work remotely and if employees are able to perform their duties in that environment, then their salary can continue to be charged to the award. For staff who normally punch in/punch out or are subject to direct supervision, alternative methods of work verification may need to be requested by a supervisor. Consult with your HR manager for specifics.
Per NSF: Allowability of salaries and other project activities. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405) Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active NSF awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. The recipient also is authorized to charge other costs to NSF awards that are necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. Recipients must not assume that supplemental funding will be available should the charging of such costs or other fees result in a shortage of funds to eventually carry out the project. If a shortfall is anticipated, recipients must contact the cognizant NSF Program Officer to discuss the situation. NSF will evaluate the grantee’s ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances—based on subsequent project reports and other communications with the recipient. Recipients are required to maintain appropriate records and cost documentation as required by 2 CFR § 200.302 – Financial management and 2 CFR § 200.333 - Retention requirement of records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services. 3/23/20
Per Office of Justice: "Allowability of salaries and other project costs: OJP will allow recipients to continue to charge salaries and benefits to their awards consistent with the recipients’ policy of paying salaries and benefits under unexpected or extraordinary circumstances from all funding sources (Federal and non-Federal). As outlined in 2 C.F.R. § 200.431 (a) and (b), benefits may include the costs of leave (“regular compensation paid to employees during periods of authorized absences from the job, such as for annual leave, family-related leave, sick leave … administrative leave, and other similar benefits”), as long as they are provided under written leave policies.OJP encourages recipients to review and update (if necessary) their written leave policies to address “unexpected or extraordinary circumstances.” Recipients are required to maintain copies of the leave policies and cost documentation (as required by 2 C.F.R. § 200.302, 2 C.F.R. § 200.333, and 2 C.F.R. § 431(b)(1)) to substantiate the charging of salaries and benefits during interruption of operations or services." 3/21/20Per DOD: "Based on OMB Memorandum M-20-17 and the uniform guidance (2 CFR 200.403, 2 CFR 200.404, 2 CFR 200.405), the DOD will allow recipients to continue to charge salaries and benefits to currently-active awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal. DOD components may allow other costs to be charged to federal awards necessary to continue work on a project even if in a period where primary research activities are limited or curtailed. To the maximum extent practicable, recipients will be expected to invoke or institute any and all reasonable mitigation actions and practices to lessen the cost to the government during the crisis period. Such actions may be part of an existing program created by the recipient or may be created to respond to this crisis. Appropriate records and cost documentation must continue to be updated and maintained as required by 2 CFR 200.302 - Financial management and 2 CFR 200.333 - Retention requirement of records." 3/24/20
Q: Normally we wouldn’t be able to pay an employee from a grant if they aren’t providing effort towards the project. Is this going to be allowed given the unique circumstances, or would need to use state funds to pay these employees during any shutdown? Has the federal government provided your office with any guidance on how people currently providing effort on grants will be paid?
A: Per the Memorandum issued by the VPR on March 26, 2020, "This memorandum and the attached Guideline G3-020 are provided to clarify the rules regarding payments from grants during the Covid-19 pandemic. As you know, federal rules generally prohibit any part of an employee’s salary or benefits to be charged to a grant except for those portions of the salary/benefits directly attributable to the employee’s work on the grant. Federal law, however, recognizes an exception to this general rule under unexpected and extraordinary circumstances. In times of emergency, when the university and its employees are unable to perform work on a grant due to the emergency, employees assigned to a grant may continue to be paid from the grant. Per OMB M-20-26, this exception is extended through September 30, 2020.
Because the current COVID-19 pandemic is requiring University employees to remain at home, many researchers do not have access to their research materials and are unable to perform much, if any, work on their grants. This is clearly the type or emergency situation contemplated by the federal regulations. Therefore, you should continue to use designated grant funding to pay the salaries and benefits of your research employees until they are able to return to their labs and continue their sponsored research.
Expenses for employees that are on paid leave (administrative, sick, vacation) qualify as appropriate direct costs under the University’s F&A Rate Agreement with the Federal Government. Those expenses should remain on the projects and the University does not have a central pool to absorb those costs.
When possible and appropriate, an employee’s effort should be redirected to other sponsored projects that may be performed from a virtual environment. To the extent that such opportunities are not available or are exhausted, employees should continue to have their salaries and benefits funded from designated grants. The University does not have a central pool to absorb these costs. Please work with your PI’s and research staff, as well as your Human Resources contact, to manage and mitigate impact to employees where possible.
To benefit from the federal exception, sponsorship funding from non-federal sources must also continue during the emergency. As with federal grants, you should redirect an employee’s work to sponsored projects that may be performed from a virtual environment. To the extent that such opportunities are not available or are exhausted, employees should continue to have their salaries and benefits funded from designated grants. Please work directly with your sponsor representatives to clarify this practice during the current pandemic. Please also work with your PI’s and research staff, as well as your Human Resources contact, to manage and mitigate impact to employees where possible.
Project cost overruns are not covered by central University funds but will be covered in order by:
- A PI’s discretionary funds
- Departmental/Division funds
- College/School funds
Faculty should not expect sponsors to provide additional project funds or extensions at this time. Supplemental funding and no-cost extensions will be at the discretion of each sponsor and made on a case-by-case basis.
PIs should contact agency program managers and other sponsor representative as soon as possible, in writing and by phone, to notify them of specific challenges and likely cost impacts. Written responses from applicable sponsors that grant permission and approval for changes (and approval for any other costs not normally chargeable to awards) should be requested and obtained by PIs, as soon as possible. The Office of Sponsored Projects can facilitate those communications as needed. Please contact your OSP representative for assistance.
Please also see the Tool Kit provided by HR to assist leaders who are having to make salary and personnel decisions.
Per NIH: NIH is allowing salary to continue to be charged to the award when no contribution can be made to the project (see NOT-OD-20-086). "If a recipient organization’s policy allows for the charging of salaries and benefits during periods when no work is performed due to the effect of COVID-19, regardless of the funding source, including Federal and non-Federal, then such charges to NIH grant awards will be allowable. NIH awarding Institutes/Centers (ICs) may request documentation to confirm the requirements of institutional policies."
Q: Is there a way to document and report the impacts of COVID-19 on sponsored projects?
A: Yes. Those managing projects being negatively affected by the current pandemic are encouraged to document and report the impacts. Submissions go directly to OSP.
To help you track current and anticipated financial disruption and expenditures on 5000 fund grants and contracts, the following tools are now available:
OSP is encouraging use of these tools to track and predict COVID related expenses, as gauging financial impact for each grant gives researchers the information to better respond to federal agencies’ specific questions. These tools can also support researchers in requesting project extensions and supplement funding.
- Financial & Business Services has created a spreadsheet to help document current COVID-19 Costs During Soft Shutdown.
Q: Research studies with a lab component already purchase gloves. Who would pay for other supplies (masks, wipes, etc.) if needed?
A: Personal protection equipment needed to perform the grant can be a direct charge. Supplies needed for cleaning should be considered an indirect cost.
Please also see PPE and Sanitation Supplies for Departmental Use (7/30/20)
Q: If staff would need to work from home, we are considering cell phones for use when contacting human subjects. Depending on the research study, it could be several phones needed. Some folks are uncomfortable with using their own home/cell phones when calling human subjects/research study participants.
A: Inexpensive cell phones used solely for the purposes of the grant would likely be a defensible charge to the grant in these circumstances, particularly for studies involving a large number of subjects. The PI/department should, however, request prior written approval of the funding agency for this unusual cost. Requests for prior approval should be submitted using that agency's normal channels. Program Officer approval itself is not normally sufficient to constitute approval. If approved, the PI/department authorizing the charges would need to oversee the purchases and use of the phones to ensure that they were used exclusively for the project; if used for multiple projects, cost allocations must reflect relative useage. Documentation should be retained in the department's grant file. As a less burdensome and costly alternative, the department may want to consider alternative technologies that allow users to shield their personal number when using their own cell phone for business purposes. For example see Google Voice:
How it works: https://www.lifewire.com/how-google-voice-works-3426682
Link to the app: https://voice.google.com/u/0/about
Please note: Google Voice should not be used in situations that involve HIPAA-protected information exchanges.
Q: If I have lab animals that need to be cared for and am concerned that staff may not be available to care for the animals or have the access they need to facilities if my institution closes.
A: The University is required to have animal care emergency plans in place as a condition to a federal award involving animal research. Consult IACUC for questions about caring for animals.