- Question 1 provides a sample template email for use in communication of project delays to sponsor Program Officer.
- Question 7 response is revised to include NIH detail.
- Question 10 is an addition to the previous FAQ’s
Q #1: I need to shut down my lab – do I need to notify my project sponsors and if so, how? (Updated 4.2.20)
A: Yes. Several funding agencies, both federal and non-federal, have expressed their willingness to provide much greater flexibilities for projects that have been adversely impacted due to COVID-19. Keeping your funder informed will help them provide flexibility to you where possible, including the future awarding of supplemental funding in some cases. ORA staff are available to look at your specific award conditions to determine if such a notification is required. In many cases, it will be required, so please err on the side of caution. You can request assistance from ORA by sending a request to email@example.com.
All federally funded projects (including pass-through) require notification to the federal agency. Uniform Guidance §200.328 provides the following:
(d) Significant developments. Events may occur between the scheduled performance reporting dates that have significant impact upon the supported activity. In such cases, the non-Federal entity must inform the Federal awarding agency or pass-through entity as soon as the following types of conditions become known:
(1) Problems, delays, or adverse conditions which will materially impair the ability to meet the objective of the Federal award. This disclosure must include a statement of the action taken, or contemplated, and any assistance needed to resolve the situation.
While you may not be able to address all of these points in your communication to your program officer due to the many unknowns and evolving nature of the impacts of COVID-19, you should address what you can. Unfortunately, agencies are currently requiring a project by project notification. An email directly to your program officer (please Cc ORA at firstname.lastname@example.org) to notify them that your project is currently impeded and any known impacts will suffice in most cases.
A generalized template has been developed to simplify your communication to your program officer. This Sponsor Notification Template is available from FAQ #1 on the COVID-19: Guidance for Research Operations website.
Q #2: I need to request a no-cost extension on my project. Who should I work with?
A: Most funding agencies are providing significant flexibilities in providing no cost extensions given the present circumstances. ORA staff will help you in submitting a request. Please email email@example.com with “NCE Request” in the subject line and ie include the account number, PI and Agency name in the body of the email. An ORA Grant Services Administrator will be assigned to assist you with the request.
IU Policy does not require a new Proposal Development document for a no-cost extension. However, most funding agencies require that an authorized official (ORA) submit the request for the no-cost extension.
Q #3: Can I and my staff continue to be paid from the project while the campus is closed?
A: In most cases, YES, they may continue to be paid from sponsored projects.
Please note that the IU campuses are not currently closed. However, the IU president has directed that supervisors allow employees to work from home if at all possible. The IU Vice President for Research has determined that as of COB March 27, 2020, in-person research activities are limited to essential research. Other research activities may only continue to the extent that they may be accomplished remotely (telecommuting).
Essential Research & Telecommuting Project Staff
Employees paid from grants supporting essential research (meaning that it continues to proceed on campus) or project activities that are being accomplished via telecommuting, you should continue to allocate compensation expenses as you would normally in terms of allocating salary to the grant proportionate to their other assigned activities. Many research and scholarly activities can be continued remotely and supported by regular electronic and virtual contact with research groups. Alternate approaches for research personnel working remotely might include data analysis, manuscript preparation and review, presentation preparation, grant report preparation, and online discussions with students and lab staff.
Project Staff Unable to Telecommute or Not Involved with Essential Research
In cases where the project work does not meet the criteria for essential research and telecommuting is not an option, you may continue to allocate compensation costs to sponsored projects subject to the following:
Grants, Cooperative agreements, and Fixed Price Contracts
Compensation paid to those that cannot work may be allocated to active awards so long as it is done so consistent with the announcement from the IU President and in accordance with IU policies. The effective date for this is March 23, 2020 and will extend through a period as defined by the IU President. Compensation costs for those not able to work should be allocated to sponsored awards at the current or planned levels. Departments should retain documentation citing the circumstances (e.g. reasons why work cannot be completed remotely) and the number of days paid while not working. PI’s should notify their program officers of any delays caused by the inability to continue work as outlined in FAQ #1 above.
Cost Reimbursable Contracts (including federal and State of Indiana)
The funder should be contacted to notify them of potential delays to the project and guidance sought as to the allowability of charging costs for employees that are unable to work and are being paid by the university outside of their normal paid time off accruals. Please note that normal paid time off accruals provided under IU Policy (sick, vacation, family leave) remain an allowable cost to cost reimbursable contracts.
Additional guidance for several federal agencies is available at: COVID-19: Guidance for Research Operations at IU.
Q #4: Do these salary guidelines apply to hourly staff as well?
A: Any type of appointments that are eligible for continued pay by IU if they are not able to work may continue to be charged to sponsored programs consistent with FAQ #3. The announcement from the IU President indicated that “faculty, staff, academic appointees including graduate students, and temporary workers” would be eligible for continued pay. Please consult HR policies and guidance for specifics on who may continue to be paid when not able to work.
Q #5: Overtime eligible staff who are designated as on campus essential receive premium of 1.5X pay for the time they are working on campus. Can this be charged to a federal grant?
A: Yes, premium pay (aka overtime or extra service pay) is allowable on all sponsored projects, including federally funded, as long as it is paid consistently with IU institutional policy, regardless of the source of funds.
Q #6: We have project-related travel that must be cancelled. What steps do we need to take? Can the prepaid costs remain on the project?
A: If the travel cost was originally incurred to benefit the project and the trip was cancelled, you may allocate the unrecoverable travel costs to the sponsored project award. In all such cases, a refund or credit for the travel should be requested. Refunds should be recorded in the sponsored project account that incurred the original travel costs. If you receive a credit for future travel (hotel, airfare, etc), the portion of expense related to the value of the credit should be transferred off of the sponsored project account. This expense may be reallocated to the grant if the travel credit is used to benefit the sponsored project in the future.
Q #7: We have been instructed to gather research PPE for future use by hospitals. If they were left over from grants and will not be used, is it OK to contribute them for this purpose? If PPE will likely be needed in the future for future grants, can they still be contributed and then repurchased through future grants? (Updated 4.2.20)
A: For NIH, yes, recipients may donate PPE and other lab supplies in support of efforts related to COVID-19. Recipients may re-budget grant funds to repurchase supplies at a later date, use large unobligated balances, or submit an administrative supplement request to the funding IC for consideration. This is further outlined in the NIH FAQ’s.
For other agencies, if the donated PPE was purchased from an active grant award, the proportional cost should be removed from that grant – which would then allow you to charge the grant in the future if that project needed more PPE. If it was purchased from an expired grant, it may be donated without offsetting the original grant award.
Q #8: I just received my new award. If I consider it essential research, can I begin working on it, and if so, do I need to notify the VPR office? Where can I find the VPR form?
A: Yes, essential research activities may begin on new projects that meet the detailed VPR criteria. Please review the criteria at https://research.iu.edu/coronavirus/index.html found under “What are Essential Research Activities”, and complete and submit the essential research activities form.
Q #9: How do I determine whether my research is essential or not?
A: Faculty should review the criteria at https://research.iu.edu/coronavirus/index.html under “What are Essential Research Activities” and make a determination to the best of their ability. If further guidance is needed, your department chair or dean should be consulted.
Q #10: NIH has provided an extension on proposals due prior to May 1. The original proposal due date for my submission was in April. Should I wait and submit my proposal on May 1? (New 4.2.20)
A: NIH’s decision to postpone submission due dates to May 1 may result in a large backlog of proposals being submitted on or shortly before that deadline. If possible, it is best to complete your proposal submission prior to the deadline. ORA staff (and likely you and your departmental staff) are working from home with varying levels of internet access. Submitting earlier than May 1 provides added flexibility to ensure these proposals are submitted smoothly.
Additional FAQ Resources
NSF - Frequently Asked Questions (FAQs) About the Coronavirus Disease 2019 (COVID-19) for NSF Proposers and Awardees
NIH - COVID-19 Flexibilities for Applicants and Recipients FAQ’s
IU - COVID-19: Guidance for Research Operations at IU
IU FAQ's Related to Research Administration and COVID-19 (Updated 4.2.20)