The Department of Defense (DOD) is aware that many in the research community have been impacted by COVID-19. The DOD is taking action to provide greater flexibility to the research community in this challenging time.
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. Based on the OMB Memorandum, please find below answers to Frequently Asked Questions by grantees and proposers about research and development awards at the DOD.
Grantees and proposers are advised that each federal agency has different authorities, and there might not be complete uniformity between agencies, components of agencies, and even between programs. The safest course of action in all cases is to contact the grants manager and program officer for the award to determine how the financial assistance award will be treated.
Q: Will I have to meet the current deadlines for reports and other deliverables related to my research award?
A: Consistent with OMB Memorandum M-20-17, the DOD will allow grantees to delay submission of financial, performance and other reports on currently-active award accounts up to three months beyond the normal due date. For any other deliverables related to research awards, please contact the DOD grants manager and/or program manager for award specific guidance.
Q: Can I get reimbursed for costs incurred due to travel cancelled because of COVID-19?
A: The DOD will allow nonrefundable travel expenses incurred for travel canceled due to COVID-19 to be charged to active awards in agreement with OMB Memorandum M-20-17. Grantees must follow applicable institution policy on allowable expenses for travel.
Q: Can I continue to charge salaries and benefits to currently-active awards for personnel who would normally be paid out of the award (e.g., graduate students, principal investigators, and postdoctoral researchers)?
A: Based on OMB Memorandum M-20-17 and the uniform guidance (2 CFR 200.403, 2 CFR 200.404, 2 CFR 200.405), the DOD will allow recipients to 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. DOD components may allow other costs to be charged to federal awards necessary to continue work on a project even if in a period where primary research activities are limited or curtailed. To the maximum extent practicable, recipients will be expected to 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 or may be created to respond to this crisis. Appropriate records and cost documentation must continue to be updated and maintained as required by 2 CFR 200.302 - Financial management and 2 CFR 200.333 - Retention requirement of records.
Q: COVID-19 closures have delayed my work. Can I receive a no-cost extension on my active award?
A: It is DOD policy that no-cost extensions must be supported in all possible cases. However, please be aware that funding expiration statutes may prohibit extensions. Please contact the DOD grants manager for award-specific guidance.
Q: There are upcoming application deadlines for a program I want to submit a proposal for. Can these be extended?
A: The DOD recommends that program offices provide flexibility with upcoming proposal deadlines to the extent allowable by funding authorities and by the need to have enough time for merit review of submitted proposals. Please contact the program officer and grants manager for the funding opportunity in question to seek an application deadline extension. Proposers are encouraged to monitor grants.gov to see if an extension has been posted.
For more information in regards to COVID-19, please visit the following links:
Coronavirus Disease 2019 (COVID-19) - https://www.coronavirus.gov
Coronavirus (COVID-19) - https://cdc.gov/coronavirus