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  • 4 Jun 2020 9:06 AM | Hawk Tran (Administrator)

    The Senate passed legislation on June 3rd to provide more flexibility for the Paycheck Protection Program (PPP), which provides help for small businesses amid the steep economic impact of the coronavirus.

    "Today we're passing another piece of legislation that makes a few targeted changes to the program," Senate Majority Leader Mitch McConnell (R-Ky.) announced from the floor. "I'm proud the Senate is sending it on to the president's desk to become law."

    The bill, which would extend the window for businesses to be able to spend loans granted under the program, passed the Senate by unanimous consent. The bill already passed the House last month, meaning it now goes to the President's desk where it is expected he will sign the bill into law.  

    The new bill passed by Congress would extend the current language to allow businesses up to 24 weeks to spend PPP funds. It would also change a 75-25 divide included in the March bill — which required businesses to spend 75 percent of the loan on payroll and 25 percent on other fixed costs such as rent and utilities. The new language will change the ratio to a 60-40 split.


  • 1 Jun 2020 1:57 PM | Hawk Tran (Administrator)

    The Society for Human Resource Management has posted a fantastic guide for HR during COVID-19. NAVREF recommends NPCs take a look at this guide or download it for their HR personnel. 

    Click here for the SHRM HR and COVID-19 GuideBook

  • 28 May 2020 10:16 AM | Hawk Tran (Administrator)

    Discussion Group Questions Related to Paycheck Protection Program

    PPP as federal financial assistance

    The SBA is on record as saying that PPP is federal financial assistance, though the citation is in the FAQs that were directed at nondiscrimination requirements at faith-based institutions:

    "5. [Q] What legal requirements will be imposed on my organization as a result of our receipt of this Federal financial assistance? Will those requirements cease to apply when the loan is either repaid in full or forgiven? 

    [A] Receipt of a loan through any SBA program constitutes Federal financial assistance and carries with it the application of certain nondiscrimination obligations.”

    We have asked whether PPP is considered as federal financial assistance for purposes of the Uniform Guidance, but the SBA has not published any FAQs that address the issue.

    Base period for calculating the FTE factor in PPP forgiveness:

    Page 16 of the interim final rule on loan forgiveness:  "In general, a reduction in FTE employees during the covered period or the alternative payroll covered period reduces the loan forgiveness amount by the same percentage as the percentage reduction in FTE employees. The borrower must first select a reference period: (i) February 15, 2019 through June 30, 2019; (ii) January 1, 2020 through February 29, 2020; or (iii) in the case of a seasonal employer, either of the two preceding methods or a consecutive 12-week period between May 1, 2019 and September 15, 2019. If the average number of FTE employees during the covered period or the alternative payroll covered period is less than during the reference period, the total eligible expenses available for forgiveness is reduced proportionally by the percentage reduction in FTE employees. For example, if a borrower had 10.0 FTE employees during the reference period and this declined to 8.0 FTE employees during the covered period, the percentage of FTE employees declined by 20 percent and thus only 80 percent of otherwise eligible expenses are available for forgiveness”.

    This interim final rule includes other details of the forgiveness calculation.  The forgiveness form and its related instructions provide the structure of the calculation.

    Cost sharing on $100,000 salary cap: 

    The treatment is the same as the one that grantees would apply to salaries over the NIH salary cap of $197,300:  the amount over the cap can’t be shifted to other federal accounts (or to the indirect cost pool) since it would shift a disproportionate amount of the compensation to the other accounts. And if the employee were a direct charge, the amount over the cap would be included in the direct cost base.  

    Per Uniform Guidance § 200.405 (b): "(c) Any cost allocable to a particular Federal award under the principles provided for in this Part may not be charged to other Federal awards to overcome fund deficiencies, to avoid restrictions imposed by Federal statutes, regulations, or terms and conditions of the Federal awards, or for other reasons."

    Per NIH GPS 4.2.10: "None of the funds appropriated in the governing appropriation Act for the NIH (the Act), shall be used to pay the salary of an individual through a grant or other extramural mechanism at a rate in excess of that prescribed in the Act. “

    Per NIH GPS 17.3:  "A grant application from a university may request the university’s share of an investigator’s salary in proportion to the effort devoted to the research project. The institutional base salary as contained in the individual’s university appointment determines the base for computing that request."

    NIH GPS definitions (salaries and wages):  "Compensation for personal services covers all amounts, including fringe benefits, paid currently or accrued by the organization for employee services rendered to the grant-supported project. Compensation costs are allowable to the extent that they are reasonable, conform to the established policy of the organization consistently applied regardless of the source of funds, and reasonably reflect the percentage of time actually devoted to the NIH-funded project." 

    Per Uniform Guidance § 200.451 "Losses on other awards or contracts. Any excess of costs over income under any other award or contract of any nature is unallowable. This includes, but is not limited to, the non-Federal entity's contributed portion by reason of cost-sharing agreements or any under-recoveries through negotiation of flat amounts for indirect (F&A) costs. Also, any excess of costs over authorized funding levels transferred from any award or contract to another award or contract is unallowable. All losses are not allowable indirect (F&A) costs and are required to be included in the appropriate indirect cost rate base for allocation of indirect costs.” 

    Per Uniform Guidance 200.430 (h)(2): Institutional Base Salary:  "(2) Salary basis. Charges for work performed on Federal awards by faculty members during the academic year are allowable at the IBS rate. Except as noted in paragraph (h)(1)(ii) of this section, in no event will charges to Federal awards, irrespective of the basis of computation, exceed the proportionate share of the IBS for that period.”  

    This is in the section on institutions of higher education, but the concept is the same. 

    Example:  Assume that an investigator earns a base salary of $180,000, and the grantee supports half of his or her salary on the PPP, and the other half on an NIH grant.  The PPP has a salary cap of $100,000, so only $50,000 is a PPP-eligible payroll cost.  That means that the institution is left with $40,000 ($180,000 times ½, less $100,000 times ½) that it cannot cover with the PPP loan.  If that amount were charged to the grant instead, then the grant would be charged $130,000 ($90,000 plus $40,000) for 50% effort.  That implies a salary rate of $260,000, which is not only over the NIH cap but is more than the institutional base salary of $180,000.  The grantee must absorb the $40,000 (as well as the allocated indirect costs on that amount). Put another way, a hypothetical charge of $130,000 to the grant would represent 72.2% of the salary, which is not "the percentage of time actually devoted to the NIH-funded project,” which is 50%.   Alternately, the grantee might claim that the employee continued to work 100% of the time on the grant, though with the PPP loan they did not charge the full $180,000 to it.  The difference of $50,000 ($180,000 less the amount not funded by the PPP--$130,000) would be cost sharing.

    The same logic would apply to FICA tax, which is not an eligible payroll cost for PPP.  It could not be charged to other awards.  If a grantee had a fringe benefits rate, they would not be able to reduce the salary and wage base for the PPP and thereby charge the ineligible amount to federal awards through the increased fringe benefits rate that would result.  If they charged fringes on an individual basis, they would simply not charge the amount associated with the individual whose payroll costs were covered by the PPP.  It would become cost sharing.  

    Audit requirement:   

    Per the AICPA web site (https://www.aicpa.org/interestareas/governmentalauditquality/newsandpublications/gaqcalert/2020gaqcarchivedalerts/gaqcalertno404.html) :  "One of the most common questions we have received is whether SBA PPP loans obtained by NFPs are subject to the Uniform Guidance single audit requirements. The good news is that we have recently received an answer to this question. Based on recent discussions with SBA staff, we have been informed that PPP loans made to NFPs will not be subject to single audit...On the other hand, SBA informed us that loans made to NFPs under the EIDL program are considered a direct loan program disbursed from SBA to loan recipients. Therefore, these loans are considered federal financial assistance and are subject to the Uniform Guidance single audit requirements.” 


  • 20 May 2020 2:03 PM | Hawk Tran (Administrator)

    The SBA released its Paycheck Protection Program (PPP) Loan Forgiveness Application and clarified a few critical definitions and documentation requirements in their instructions. The forgiveness application is completed by the small-business borrower and then submitted to their bank or lender whom they received their PPP loan from. The application consists of 11 lines that when calculated results in the amount of forgiveness a small-business owner will be eligible for. 

    NAVREF has posted the SBA loan forgiveness application form 3508 on the COVID-19 Response Page for our member's convenience. 


  • 6 May 2020 12:27 PM | Hawk Tran (Administrator)

    The U.S. Small Business Administration (SBA), in consultation with the U.S. Department of the Treasury, has extended the deadline to repay Paycheck Protection Program (PPP) loans by one week.

    In further response to the SBA's recent guidance in FAQ 31 reminding borrowers to review carefully the certification required for PPP loans that "[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant" and providing a safe harbor to repay any PPP loan by May 7, 2020, so as to avoid any contention that such certification was not in fact made in good faith, the SBA released FAQ 43 on May 5, 2020.

    In FAQ 43, the SBA advises that:

    • SBA is extending the repayment date for the safe harbor to May 14, 2020.
    • Borrowers do not need to apply for this extension.
    • The extension will be promptly implemented through a revision to the SBA's interim final rule providing the safe harbor.
    • SBA intends to provide additional guidance on how it will review the certification prior to May 14, 2020.

    Borrowers of PPP loans should consider carefully both the new deadline and the expected additional guidance on how the SBA will review certifications, if feasible, before submitting an application or deciding whether to retain borrowed PPP funds.


  • 5 May 2020 9:32 AM | Hawk Tran (Administrator)

    https://www.sba.gov/sites/default/files/2020-05/Paycheck-Protection-Program-Frequently-Asked-Questions_05%2003%2020.pdf

    The Paycheck Protection Program has undoubtedly been a critical SBA loan program for small business, but implementation has also raised several questions. The link above will help answer some of the most frequently asked questions concerning PPP and can be interpreted as final guidance for lenders as well. 

  • 16 Apr 2020 9:02 PM | Hawk Tran (Administrator)

    In case you've missed it, the VA Office of Research and Development has been sending out newsletters updates pertaining to COVID-19. In an effort to ensure the widest distribution, NAVREF will begin posting the newsletters here on the COVID-19 blog as well as forwarding them to NPC Executive Directors. Be sure to check you spam folders and subscribe to this blogs RSS feed for updates! 

    ORD COVID-19 Newsletter - April 13

  • 7 Apr 2020 9:06 AM | Hawk Tran (Administrator)

    Curious about the SBA loans becoming available? NAVREF held a webinar this past Friday discussing the Paycheck Protection Program and the Economic Injury Disaster Loan. In case you missed it, you can re-watch the recorded webinar via this link: https://attendee.gotowebinar.com/recording/4461792203233942796 

    Click the links below for the presentation materials:

    1. Presentation
    2. Handout
  • 27 Mar 2020 1:20 PM | Hawk Tran (Administrator)

    On March 19, 2020 OMB issued Memorandum M-20-17 Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations (https://www.whitehouse.gov/wp-content/uploads/2020/03/M-20-17.pdf). The Department of Defense (DoD) also recently published Frequently Asked Questions (FAQs) (https://basicresearch.defense.gov/COVID-19/Frequently-Asked-Questions/). The United States Army Medical Research Acquisition Activity (USAMRAA) will apply, to the maximum extent possible, all the allowed exceptions to our financial assistance awards, including allowance of costs. The following exceptions, aligned with the format in Memorandum M-20-17 and guidance from the DoD, are time limited. OMB anticipates reassessing the exceptions within 90 days.

     

    1. Flexibility with SAM registration:

     

    • The SAM registration process will be relaxed as outlined in M-20-17.

     

    2. Flexibility with application deadlines:

     

    • There are currently no plans to modify existing application deadline dates but please continue to monitor Grants.gov for any potential change(s) to an application deadline.
    • Please contact the CDMRP Help Desk at help@eBRAP.org or 301-682-5507 if you need further assistance.
    • This response may be updated at a later date depending on whether application review panel meeting dates are revised. Please check this page periodically for possible updates.

     

    3. Waiver of Notice of Funding Opportunities Publication:

     

    • USAMRAA has no immediate emergency Program Announcements for grants or cooperative agreements available at this time.
    • This response may be updated at a later date depending on whether application review panel meeting dates are revised. Please check this page periodically for possible updates.

     

    4. No-cost extensions on expiring awards:

     

    • USAMRAA’s terms and conditions of award already allow for a one-time, no cost extension of up to 12 months, without need to request prior approval, when the recipient notifies the Grants Officer (GO).
    • Recipients may notify USAMRAA’s GO(s) of a blanket no-cost extension on all active awards(including grant numbers) covered under M-20-17 -- i.e., they do not need to be requested on an individual basis for each award.
    • However, please be aware that funding expiration statutes may prohibit extensions. Recipients should contact the USAMRAA GO for award-specific guidance.

     

    5. Abbreviated continuation requests:

     

    • Not applicable for USAMRAA grants and cooperative agreements.

     

    6. Expenditure of award funds for salaries and other project activities:

     

    • Recipients may 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.
    • USAMRAA will allow 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. This may include allowing rent on equipment and facilities during this time frame.

    oHowever, to the maximum extent practicable, recipients must 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 organization or may be created to respond to this crisis.

    • 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 salaries and other project activities costs related to interruption of operations or services.

     

    7. Allowability of Costs not Normally Chargeable to Awards.

     

    • USAMRAA will allow recipients who incur costs related to the 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 these costs to their award without regard to 2 CFR § 200.403, Factors affecting allow ability of costs, 2 CFR §200.404, Reasonable costs, and 2 CFR § 200.405, Allocable costs.
    • USAMRAA will allow recipients to charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant.
    • However, recipients should not assume 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 are required to maintain appropriate records and cost documentation as required by2 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.

     

    8. Prior approval requirement waivers:

     

    • OMB and DoD have authorized awarding agencies to waive prior approval requirements as necessary. Some prior approvals are already waived under the DoD General Research &Development Terms and Conditions and USAMRAA’s agency-specific terms conditions.
    • Recipients should consult their GO regarding other potential prior approval waivers based on project-specific circumstances.
    • All costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award, except where specified in OMB Memorandum M-20-17.

     

    9. Exemption of certain procurement requirements:

     

    • The procurement requirements contained in 2 CFR 200.319(b) regarding geographic preference and 2 CFR 200.231 regarding contracting with small and minority businesses, women’s business enterprises, and labor surplus supply firms are waved in order to expedite the procurement process for needed support during the period outlined in OMB Memorandum M-20-17.

     

    10. Extension of financial and other reporting:

     

    • Recipients may delay submission of financial, performance and other reports on currently active award accounts up to three (3) months beyond the normal due date.
    • Contact the GO and Grants Officer’s Representative (GOR) for extensions on other milestones and deliverables required in the terms and conditions of the award. If warranted, the same three-month extension may be granted.
    • Recipients may continue to invoice for payment of Federal funds without timely submission of reports.
    • Reports must be submitted at the end of the postponed period. Additional extensions require prior approval of the GO.

     

    11. Extension of currently approved indirect costs rates:

     

    • Recipients may continue to use the currently approved indirect cost rates (i.e., predetermined, fixed, or provisional rates) to recover their indirect costs on Federal awards.
    • Recipients may contact their cognizant agency for indirect costs to request an extension on the use of the current rates for one additional year without submission of an indirect cost proposal. The cognizant agency may also approve requests for an extension of the indirect cost rate proposal submission to finalize the current rates and establish future rates.

     

    12. Extension of closeout:

     

    • Recipients may delay submission of any pending financial, performance and other reports required by the terms of the award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the grantee to the GO.
    • This delay in submitting closeout reports may not exceed one year after the award expires.

     

    13. Extension of Single Audit submission.

     

    • Implemented as stated in M-20-17.

     

    14. The COVID-19 pandemic has impacted the conduct of my DoD-supported human subjects research protocol. What do I need to report to the USAMRDC Human Research Protection Office (HRPO)?

     

     

    15. ACURO Guidance During the COVID-19 Pandemic

     


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