Public Health Emergency - Leading a Nation Prepared
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.
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.
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.
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).
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.
Please contact the Office of Contracts and Grants for any questions. You may send requests to the ASPR Resource inbox available at
email@example.com or if you have an assigned Grants Management Specialist (GMS) and Federal Project Officer (FPO), contact them directly.
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