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DoD and NIH reactions to recent OMB Guidance

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.


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