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)?

 

• For guidance, visit https://mrdc.amedd.army.mil/index.cfm/collaborate/research_protections/hrpo/faqs

 

15. ACURO Guidance During the COVID-19 Pandemic

 

• For guidance, visit https://mrdc.amedd.army.mil/assets/docs/orp/acuro/ACURO_Guidance_for_COVID-19.pdf

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 

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.

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

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:

• Visit the NAVREF website for current information (www.navref.org)
• Participate in the NAVREF Forum to share information and ask questions (www.navref.org/forum)
• Respond to the SCRS site survey to give voice to your COVID-19 concerns as VA-affiliated sites (https://myscrs.az1.qualtrics.com/jfe/form/SV_6zDfXTmPlz3Tqnj)
• Check with your state Small Business Administration to determine your eligibility for a disaster assistance loan and application procedures (note that nonprofits are considered eligible per the SBA press release on March 12^th).

• Attend the ORD webinar on Thursday at 2:30 pm ET.  The presenters will discuss strategies for handling ORD-funded research-related activities in the context of COVID-19 in the VA.  Webinar registration:   https://attendee.gotowebinar.com/register/4368294131989473035

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