The Office of Management of Budget (OMB) has issued additional relief to recipients and applicants of federal financial assistance due to the impact of the novel coronavirus (COVID-19) outbreak and the loss of operations. The OMB lists 13 provisions authorizing federal awarding agencies to implement as they deem appropriate and as permitted by law, including:
Flexibility with System for Award Management (SAM) registration. Provides the capability to relax active SAM registration at time of application in order to expeditiously issue funding. Current registrations that expire before May 16 will be afforded a one-time, 60-day extension.
Flexibility with application deadlines. Agencies have been asked to provide specific guidance on their websites re their flexibility with the submission of applications.
Waiver for Notice of Funding Opportunities (NOFO) publication. Awarding agencies can publish emergency NOFOs for less than 30 days.
No-cost extensions on expiring awards. Agencies may extend automatically awards active as of March 31 and scheduled to expire up to December 31, 2020 at no-cost for a period of up to 12 months.
Abbreviated noncompetitive continuation requests. Asks recipients to verify that they are in a position to resume or restore project activities and accept a planned continuation award.
Allowability of salaries and of project activities. Recipients can continue to charge salaries and benefits to currently active federal awards consistent with the recipient’s policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources. Agencies may also allow to be charged to federal awards other costs necessary to resume activities supported by the award, consistent with applicable cost principles. Recipients are reminded to maintain appropriate records; cost documentation is required.
Allowability of costs not normally chargeable to awards. Agencies may allow recipients that incur costs related to cancellation of events, travel or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant-funded activities due to the public health emergency to charge costs to their award. Recipients are reminded that they should not assume additional funds will be available should the charging of these costs result in a shortage of funds to eventually carry out the purpose of the project.
Prior approval requirement waivers. Awarding agencies are authorized to waive prior approval requirements.
Exemption of certain procurement requirements. With regard to geographical preferences, and regarding contracting small and minority businesses, womens’ business enterprises and labor surplus area firms.
Extension of financial, performance and other reporting. Grantees may be permitted to delay submission of required reports for up to three months beyond the normal due date.
Extension of currently approved indirect cost rates. Grantees may be permitted to use the currently approved IDR, and agencies may approve grantee requests for an extension of use of current rates for one additional year.
Extension of closeout. Agencies may grant delays in the submission of any pending financial and other reports, and may not be more than one year after the award expires.
Extension of Single Audit submission. Permits recipients with fiscal year-ends through June 30, 2020, to delay Single Audit reporting to six months beyond the normal due date.
Recipients of federal financial aid should familiarize themselves with these additional flexibilities. If you have any questions, please contact a member of the Schneider Downs Not-For-Profit team.
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Material discussed is meant for informational purposes only, and it is not to be construed as investment, tax, or legal advice. Please note that individual situations can vary. Therefore, this information should be relied upon when coordinated with individual professional advice.