New Jersey Institute of Technology
NJIT Research Continuity Plan UpdateGuidance on Financial Management of Grants and ContractsMarch 26, 2020The Office of Management and Budget issued a memorandum on 19 March 2020 (OMB 20-17 ) providing guidance on issues related to grant management during the COVID-19 disruption. This memorandum provides short term relief for administrative, financial management, and audit requirements under 2 CFR Part 200, Uniform Administrative Requirements, Cost principles and Audit Requirements for Federal Awards, for the management of grants and contracts from all federal and non-federal sources under the public health emergency caused by COVID-19 without compromising Federal financial assistance accountability requirements.Funding agencies such as NSF and NIH have started to follow the OMB guidance with respect to grant management during this disruption to university business and research. The following parts of the OMB Memorandum M-20-17 provide important information on the financial management of the research grants and contracts. No-cost extensions on expiring awards. (2 CFR § 200.308) To the extent permitted by law, awarding agencies may extend awards which were active as of March 31, 2020 and scheduled to expire prior or up to December 31, 2020, automatically at no cost for a period of up to twelve (12) months. This will allow time for recipient assessments, the resumption of many individual projects, and a report on program progress and financial status to agency staff. Project-specific financial and performance reports will be due 90 days following the end date of the extension. Awarding agencies will examine the need to extend other project reporting as the need arises. Abbreviated non-competitive continuation requests. (2 CFR § 200.308) For continuation requests scheduled to come in from April 1, 2020 to December 31, 2020, from projects with planned future support, awarding agencies may accept a brief statement from recipients to verify that they are in a position to: 1) resume or restore their project activities; and 2) accept a planned continuation award. Awarding agencies should post any specific instructions on their website. Awarding agencies will examine the need to extend this approach on subsequent continuation award start dates as recipients have an opportunity to assess the situation. Allowability of salaries and other project activities. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405) Awarding agencies may allow recipients to continue to charge salaries and benefits to currently active Federal awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Awarding agencies may 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. Awarding agencies may also evaluate the grantee's ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances based on subsequent progress reports and other communications with the grantee. Awarding agencies must require recipients to 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. Allowability of Costs not Normally Chargeable to Awards. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405) Awarding agencies may 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 allowability of costs, 2 CFR § 200.404, Reasonable costs, and 2 CFR § 200.405, Allocable costs. Awarding agencies may allow recipients to charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant. Awarding agencies must advise recipients that they 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. Awarding agencies must require recipients to 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 cancellation or other fees related to interruption of operations or services. As appropriate, awarding agencies may list additional guidance on specific types of costs on their websites and/or provide a point of contact for an agency program official. Each agency will determine how they will implement the guidance provided by the Office of Management and Budget. Links to current notifications from federal agencies are provided below. Principal investigators should check with the websites of their specific funding agencies for more information. The Office of Research will continue to compile links for agency-specific guidance. The updates will be included in forthcoming Office of Research Newsletters and also posted on website . Office of Research Administration OperationsAll Office of Research processes continue during this period of remote operation. Our hours of usual operation remain 8:30-4:30 Monday through Friday. All staff are available by email and most have their office phone numbers forwarded to them through Cisco Jabber. You should receive a reply to an inquiry within 24 hours. You may always reach out to your college’s research administration support person for assistance.Principal investigators who have subaward activity with other institutions or contracts with industry partners are asked to discuss the current situation with their counterparts to determine if the COVID-19 disruption will require a modification to our existing agreements. If it is determined that a modification is required, please contact Justin Samolewicz at Justin.m.samolewicz@njit.edu to discuss next steps.Budget transfers or other actions needed to comply with this guidance should follow the standard procedures. Questions or concerns regarding post-award financial activity on grants may be directed to your grant accountant or Mariel Diaz at mailto:mariel.diaz@njit.edu. Questions related to OMB guidance, research compliance or general concerns about the administration and financial management of grants and contracts may be directed to Eric Hetherington, Executive Director, Sponsored Research Programs Administration at erich@njit.eduPlease also use the following group email addresses for your specific questions in the respective areas:Pre-Award inquiries: srard@njit.eduPost-Award financial management: gca@njit.eduInstitutional Review Board: irb@njit.eduInstitutional Biosafety Committee: ibc@njit.eduAll other research-related inquiries during an emergency should be submitted via _______________________________________________Coronavirus (COVID-19) Information on Sponsored Research Grants and Contracts Office of Management and BudgetFull text of OMB M-20-17: National Institutes of HealthInformation on research impact: grants funding:? grant management:? Community GuidanceImpact on Existing Deadline DatesImportant Notice No. 146 - NSF Letter to Community Regarding COVID-19 Asked Questions (FAQs) About the Coronavirus Disease 2019 (COVID-19) for NSF Panelists - March 17, 2020NSF Guidance for Major Facilities and Contracts Regarding COVID-19NSF Research on Coronavirus (COVID-19)Dear Colleague Letter on the Coronavirus Disease 2019 (COVID-19)?— RAPIDFrequently Asked Questions (FAQs) regarding the NSF Dear Colleague Letter on the Coronavirus Disease 2019 (COVID-19) (NSF 20-052)Dear Colleague Letter: Provisioning Advanced Cyberinfrastructure to Further Research on the Coronavirus Disease 2019 (COVID-19)?— RAPIDDear Colleague Letter: Request for SBIR/STTR Phase I Proposals Addressing COVID-19NSF Supporting Research to Address Coronavirus Disease blogDepartment of EnergyCOVID-19 Hub Memorandum for Applicants and Awardee (March 13)Department of Defense COVID-19 FAQs for Grant Applicants and Recipients (March 16)Coronavirus: DOD Response DARPA FAQsNational Aeronautics and Space AdministrationAdministrator Statement on Agency Response to Coronavirus (March 19) ................
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