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NAVREF COVID-19 Response Page

             

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  • 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

     


  • 26 Mar 2020 12:30 PM | Hawk Tran (Administrator)

    The COVID-19 virus has, without a doubt, had serious impacts on our daily lives and disrupted business operations throughout the country. The result of augmentations and adaptations to operations have become increasingly vital to the sustainment and survival of businesses. In an effort to to harness this dynamic for our NPCs, NAVREF will be hosting regularly scheduled virtual discussion forums as long as needed during these uncertain times. Executive Directors and their Senior Staff will receive virtual discussion invitations from NAVREF and be grouped according to NPC size. We hope these groups will be helpful for colleagues to exchange ideas and brainstorm solutions to navigate the future of the NPC community. 

    If you have not received information or would like to receive information about these virtual discussion forums, please contact Hawk Tran at htran@navref.org 

  • 23 Mar 2020 3:39 PM | Hawk Tran (Administrator)

    OMB has issued broad guidance to federal agencies about giving administrative relief to recipients of federal awards.  Unfortunately, while the OMB grants federal agencies the permissions and authority to take certain actions, it does not direct or require them to do so.  We’ve seen NIH and DOD come out with more specific guidance on some of these items and in one case—charging salaries when no work is being performed—the two agencies are handling it differently. 

    According to DoD:

    https://www.usamraa.army.mil/Shared%20Documents/COVID-19%20FAQs%20-%20USAMRAA_CLEAN.pdf

    “The Department of Defense (DoD) will only allow recipients to charge salaries and benefits to currently active awards for work actually performed to meet the project activities, regardless of the location where those duties are performed (i.e., telework eligible).”

     

    According to NIH: 

    NIH: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-086.html

     

    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.”

     

    Therefore, in the case of NIH awards, NPCs should consider developing an institutional policy of paying people who are unable to work.


  • 20 Mar 2020 3:32 PM | Hawk Tran (Administrator)

    On March 9, 2020, OMB 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.

    Please click this link to read the memo put out by OMB concerning guidance on administrative relief: https://www.whitehouse.gov/wp-content/uploads/2020/03/M-20-17.pdf


  • 18 Mar 2020 1:37 PM | Hawk Tran (Administrator)

    Gray & Associates have released a synopsis concerning the on-going developments in Congress to control the spread of COVID-19. Please refer to this document here. It can also be found in the "Links and Documents" section on the NAVREF COVID-19 Response Page.

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