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CLICK HERE TO GO TO THE NAVREF COVID-19 RESPONSE PAGE
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:
2. Flexibility with application deadlines:
3. Waiver of Notice of Funding Opportunities Publication:
4. No-cost extensions on expiring awards:
5. Abbreviated continuation requests:
6. Expenditure of award funds for salaries and other project activities:
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.
7. Allowability of Costs not Normally Chargeable to Awards.
8. Prior approval requirement waivers:
9. Exemption of certain procurement requirements:
10. Extension of financial and other reporting:
11. Extension of currently approved indirect costs rates:
12. Extension of closeout:
13. Extension of Single Audit submission.
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
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 email@example.com
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:
“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:
“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.
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.
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.
These are certainly unique times requiring unprecedented actions. We hope you, your families, and your staffs are staying healthy and safe. Our highest priority during this time should be the health and safety of families, friends, colleagues, patients, and neighbors. In many cases, this means working from home and in some cases it means slowing or stopping business operations. One of our biggest challenges is dealing with the uncertainty. Our businesses are inter-connected with so many controlling factors that a shortfall in just one area can have significant and lasting consequences for the enterprise.
The NAVREF Board held our regularly scheduled quarterly board meeting on Monday. Instead of being together in Dallas, we were looking at each other through computer screens via GoToMeeting. We tried to find ways in which we could possibly help the NPCs get through these difficult times. We spoke with Dr. Ramoni about the expected impacts to VA research and the NPCs. Please see attached guidance on ORD-funded research signed by Dr. Ramoni that was disseminated last night. Note that decisions about externally-funded research are being left to each facility.
We are aware of communication from a number of pharma sponsors who are placing enrollment holds on open studies. Please see attached message from Boehringer-Ingelheim as one example. Reach out to your sponsor with any study-specific questions. As Krissa gets information from sponsors, she will immediately share with impacted sites and we will post to our website.
We will continue to advocate for the NPCs and raise visibility of NPC issues to VA and congressional leaders as necessary. We encourage you to reach out directly to us with any concerns, requests for action, or recommendations. We will make information available to you as quickly and as efficiently as possible to help reduce the uncertainty. We recommend you consider the following options:
Ours is a community with great spirit and camaraderie. Continue reaching out to each other to keep spirits up and to stay connected. Your NAVREF team remains fully-engaged, available to you, and committed to the on-going success of you and your nonprofit.
Be well, be safe, be strong.
Rick, Hawk, & Krissa
As part of NAVREF’s mission to advance the success of the VA-affiliated research and education corporations, we host an annual conference and several workshops throughout the year. These meetings are essential opportunities to learn best practices, engage your peers, and build connections. However, we are also committed to the health and safety of our members, and we are always vigilant about monitoring the local conditions where these events are held.
COVID-19 is a developing situation and, like all of you, we are monitoring it closely. We are continuing to confidently plan for the NAVREF Annual Conference September 13-16, 2020 in Washington DC, the NPC Essentials Workshop April 16-17, 2020, in Denver, and a potential Grants Management Workshop in July 2020. We currently have no plans to postpone or cancel either of the scheduled events.
We remain in close contact with hotel representatives on sanitary, health, and other measures that should be in place at the facilities hosting these events. We continue to monitor guidelines from the World Health Organization, Centers for Disease Control and Prevention, and other pertinent public health organizations as part of our collective responsibility to focus on the facts and to act with common sense and sound judgment. As part of our balanced approach, we are also evaluating our options for virtual presentation should this option be needed.
Members are advised to check the NAVREF website. We will update it regularly as the situation evolves and make sure it contains links to reliable public health resources.
We look forward to seeing some of you in Denver and all of you later this year in DC!
Links Updated as of March 10, 2020:
Colorado COVID-19 Information: https://www.denvergov.org/content/denvergov/en/environmental-health/news/coronavirus-info.html
CDC COVID-19 Information: https://www.cdc.gov/coronavirus/index.html
WHO COVID-19 Information: https://www.who.int/emergencies/diseases/novel-coronavirus-2019
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