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U.S. Department of Health and Human Services

ASPR Guidance on Administrative Relief under OMB M-20-11

March 25, 2020


On March 9, 2020, 0MB issued M-20-11, "Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly impacted by the Novel Coronavirus (COVID-19)," to provide agencies with additional flexibilities for grants assisting the response to COVID-19.

The scope of the M-20-11 was narrowly crafted to provide flexibility to grant recipients performing essential research and services necessary to carry out the emergency response related to COVID-19.
On March 19, 2020, OMB issued M-20-17 with similar administrative relief listed in M-20-11 to an expanded scope of recipients affected by the loss of operational capacity and increased costs due to the COVID-19 crisis. Many of the operational impacts and costs are unknowable at this point, as they will depend on the spread of the coronavirus and response dictated by public health needs.

The M-20-17 memorandum provides short term relief for administrative, financial management, and audit requirements under 2 CFR Part 200, Uniform Administrative Requirements, Cost principles and Audit Requirements for Federal Awards, without compromising Federal financial assistance accountability requirements.

As recipients consider administrative relief, they should be prudent in their stewardship of Federal resources which includes giving consideration to potential offsets-e.g. reduction in training and travel.
ASPR will consider all requests on a case-by-case basis in accordance with 2 CFR § 200.102, Exceptions. Recipients are requested not to incur costs related to COVID-19 and to contact their respective Grants Management Specialists and Federal Project Officers in a timely manner for relief. Please be advised, all referenced exceptions are time limited and will be reassessed by 0MB within 90 days of this Memo.

ASPR will consider any request from recipients regarding the following waivers on a case- by – case basis.

  1. Flexibility with SAM registration. At the time of award, the requirements of 2 CFR § 200.205, Federal awarding agency review of risk posed by applicants, continue to apply. Current registrants in SAM with active registrations expiring before May 16, 2020 will be afforded a one-time extension of 60 days.

  2. Flexibility with application deadlines. (2 CFR § 200.202) ASPR has streamlined the application submission process to afford applicants ample time to submit their proposals. Information for application submission will be provided to all respective ASPR applicants. Unsolicited applications will be afforded similar flexibility in submission of applications.

  3. Waiver for Notice of Funding Opportunities (NOFOs) Publication. (2 CFR § 200.203) For competitive grants and cooperative agreements, ASPR has streamlined the application submission process to a less than 30 days to afford applicants for COVID-19 funding only at this time.

  4. No-cost extensions on expiring awards. (2 CFR § 200.308) ASPR will continue to require recipients to request no cost extensions 90 days prior to the end of period of performance and no cost extensions will be considered on a case by case basis.  Exception- ASPR’s decision making process for those recipients funded under awards with statutory language explicitly specifying date for end of performance period will be based on legal authorities.

  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, ASPR has streamlined the application submission process to afford continuation applicants ample time to submit their proposals. 

  6. Allowability of salaries and other project activities. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405). Per guidance issued by Office of Management and Budget (OMB) Memo M-20-11 and M-20-17, ASPR recipients may continue to charge salaries and benefits to currently active awards consistent with their organization's policy of paying salaries under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal. ASPR will specifically consider requests of 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. Recipients must maintain appropriate records and documentation to support the charges against the Federal awards 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.

  7. Allowability of Costs not Normally Chargeable to Awards. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405) ASPR recipients may charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant. Recipients should not assume that additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel.

Recipients must 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 cancellation or other fees related to interruption of operations or services.

  1. Prior approval requirement waivers. (2 CPR § 200.407) ASPR has streamlined the prior approval process for general administrative process such as revised budgets and carryover requests at this time. All other prior approval requests remain in effect and will receive consideration for streamlining on a case-by case basis. All costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award, except where specified in this memorandum.

  2. Exemption of certain procurement requirements. (2 CPR§ 200.319(b), 2 CPR§ 200.321) ASPR will consider on a case-by-case basis, all requests from recipients to 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.

  3. Extension of financial, performance, and other reporting. (2 CPR§ 200.327, 2 CPR§ 200.328) ASPR will consider all requests for extended submission of financial, performance and other reports up to three (3) months beyond the normal due date. Recipients will continue to draw down Federal funds without the timely submission of these reports. However, these reports must be submitted at the end of the postponed period.

ASPR request recipients continue to send notification of adverse conditions related to COVID-19 on a grant by grant basis (200 CPR 200.328(d)(l).

  1. Extension of currently approved indirect cost rates. (2 CPR§ 200.414 (c)) ASPR will allow recipients 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. ASPR will consider on a case-by-case basis all requests for an extension on the use of the current rates for one additional year without submission of an indirect cost proposal. 

In addition, ASPR will also consider on a case-by-case basis an extension of the indirect cost rate proposal submission to finalize the current rates and establish future rates.

  1. Extension of closeout. (2 CPR§ 200.343) ASPR will consider on a case-by-case basis all requests for extended submission (not to exceed one year after expiration of award) of any pending financial, performance and other reports required by the terms of the award for the closeout of expired projects.

  2. Extension of Single Audit submission. (2 CFR § 200.512) ASPR will 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.
Per guidance issued by the Office of Management and Budget in Memo M-20-11, ASPR recipients with awards issued in response to COVID-19 may delay their submission by up to 12 months.
Recipients and subrecipients must maintain documentation of the reason for the delayed filing. Recipients and subrecipients taking advantage of this extension would still qualify as a "low-risk auditee" under the criteria of 2 CFR § 200.520 (a)- Criteria for a low-risk auditee.

 

Please contact the Office of Contracts and Grants for any questions.  You may send requests to the ASPR Resource inbox available at asprgrants@hhs.gov  or if you have an assigned Grants Management Specialist (GMS) and Federal Project Officer (FPO), contact them directly.

Thank you.

 

  • This page last reviewed: March 26, 2020