Office of Research Administration COVID-19 Guidance

(Updated July 13, 2020)

This webpage is intended to provide supplemental guidance to Caltech personnel regarding management of sponsored awards that may be impacted by the COVID-19 events.

Quick Links to Topics Covered below:

Caltech Resources
Office of Research Administration Status
Federal Sponsors
Proposal Deadlines (in general)
Charges to Federal Awards Related to COVID-19 (in general)
Sponsor-Specific Guidance
National Institutes of Health
National Science Foundation
National Aeronautics and Space Administration
Department of Energy
Department of Interior (including USGS)
Department of Defense
Army Congressionally Directed Medical Research Program
Air Force Office of Scientific Research
Office of Naval Research

Cancelled (7/13/2020)!!  Temporary Policy on Charging Costs to Sponsored Awards During the COVID-19 Situation (see Notice to  Division Chairs and Division Operations Officers)

Caltech's COVID-19 Webpage (campus-wide guidance)
Caltech Office of Research Compliance Webpage (laboratory-specific guidance)
Caltech IMSS Webpage (telecommuting resources)

Office of Sponsored Research:  OSR is fully staffed. Staff are telecommuting, but with the intent of continuing to provide full services. Since staff have been directed to work remotely, they may not be able to respond as quickly to questions they receive that, for example, require access to physical files. Please note that telecommuting should not impact OSR's ability to submit sponsored proposals on time. 

Export Compliance Office:  The export office is telecommuting and is fully operational via email and phone.  Please note that some staff members are experiencing school or day-care closures, so there may be a slight delay in addressing your questions or transactions.

The Office of Management and Budget has issued a Memorandum (M-20-17; 3/19/2020) to federal agencies giving them permission to provide administrative relief to "recipients affected by the loss of operational capacity and increased costs due to the COVID-19 crisis".  However, federal sponsors must issue specific guidance before Caltech can benefit from any administrative relief.

The Council on Governmental Relations (COGR) has issued FAQs with suggested guidance to universities on how to manage federal awards impacted by COVID-19; this guidance is in anticipation of specific instructions from federal agencies.  The general message from COGR is to follow institutional policies and procedures and maintain consistent treatment of costs across all institutional fund sources; Caltech is adhering to this guidance in the absence of specific agency guidance. 

COGR is maintaining a list of key COVID-19 resources, including links to agency-specific guidance:

https://www.cogr.edu/cogrs-faqs-and-resources-covid-19s-impact-federal-awards

In addition, COGR has created a Federal Agency Guidance Matrix summarizing the information provided by each agency. 

New (7/13/2020)!!  OMB issued Memorandum M-20-26 on 6/18/2020, which ends most of the flexibilities provided by M-20-17.  Regarding the one remaining flexibility applicable to Caltech, "Allowability of Salaries and other Project Activities", OMB extended this flexibility to 9/30/2020 but added conditions that Caltech was unable to accept.  As a result, Caltech has chosen to cancel its Temporary Policy on Charging Costs to Sponsored Awards During the COVID-19 Situation (see Notice to  Division Chairs and Division Operations Officers).

Many agencies have issued deadline extensions to specific program announcements, but one must usually review each specific announcement to determine whether an extension has been approved.  See specific sponsor guidance below.

Federal regulations require that charges to federal awards must be allowable under the award terms and must be consistent with institutional policy. To the extent that a federal agency provides administrative relief for awards impacted by COVID-19 (e.g., the cost of trip cancellation costs, or the cost of project personnel unable to actively work on the project), these costs may only be charged to federal awards to the extent institutional policy allows.  Please continue to follow Caltech policies and procedures when making charges to sponsored awards, including:

Cancelled (7/13/2020)!! Temporary Policy on Charging Costs to Sponsored Awards During the COVID-19 Situation (see Notice to  Division Chairs and Division Operations Officers)

Temporary Personnel Memorandum

The sponsor-specific guidance below applies to proposals for, and awards issued as, federal financial assistance (grants and cooperative agreements). 

Federal contract proposal deadlines are as stated in each respective RFP.  Management of federal contract awards is as required by the contract's terms and conditions.  PIs who need administrative relief from a contract's performance requirements as a result of COVID-19 events must discuss their situation directly with the responsible program officer.

NIH is the first federal agency to issue detailed guidance; it did so prior to OMB's instruction to federal agencies referenced above. Please see the following NIH webpage which pulls together its various guidance documents:

https://grants.nih.gov/grants/natural_disasters/corona-virus.htm

In summary:

NIH Proposals:  NIH has issued a statement extending deadlines to 5/1/2020 for applications due between March 9 and May 1; NIH will extend FOAs that are due to expire prior to 5/1 to allow for applications to be submitted after the current deadline.  NIH's policy for all other applications affected by COVID-19 is that PIs may submit late but must include cover letter with application explaining situation; program officer will make final decision as to whether the PI's situation warrants acceptance of a late proposal.

NIH Awards: Progress reports may be submitted late, if delayed due to COVID-19, but the PI must contact the program official prior to the due date to let them know that the report will be late.  Subsequent funding decisions by NIH may be late as a result of late progress reports.

NSF is the first agency to issue guidance following the OMB instruction referenced above.  Following is NSF's COVID-19 page:

https://www.nsf.gov/news/special_reports/coronavirus/

In summary:

NSF Proposals: NSF has extended the deadline dates for specific funding opportunities. A listing of these extensions (updated 4/1/2020) is available on NSF's COVID-19 webpage; deadline dates for funding opportunities that do not appear on the list remain unchanged.  PIs who are unable to meet stated deadlines should contact the cognizant NSF Program Officer to discuss the issue; NSF will consider extensions on a case-by-case basis.

NSF Awards: NSF has extended the due date of all annual and final project reports, due between March 1 and April 30, 2020, by 30 days; the same applies to Project Outcomes Reports.  New awards or supplemental funding will be delayed by NSF until all required reports are submitted. 

(4/1/2020) Prior approval requirements, except for those identified in  the NSF implementation, are waived.

(4/1/2020)

NASA Proposals: NASA may extend deadlines on a program-by-program basis.  PIs should communicate directly with the relevant Program Office if they cannot meet a proposal deadline.

NASA Awards: Financial, performance and other reports may be submitted up to 3 months beyond the normal due date.  However, awardees must notify their program and grant officers if they intend to take this action.  Report reminders will continue to be issued by NASA based on the original due date.

https://www.nssc.nasa.gov/grants

DOE has issued guidance for both proposal submission and award management.  In summary: 

DOE Proposals: Pre-application, LOI and full proposal deadlines may be extended by no more than 14 days from the original due date if the lead PI or the applicant institution are subject to a quarantine or a closure.  PIs must contact the program manager of the opportunity prior to the original deadline in order to arrange for this extension.  (4/1/2020) DOE will determine whether deadline extensions are necessary for specific opportunities.

DOE Awards:  (4/1/2020) Grantees must inform the DOE contract officer if they need an extension to any reporting due date. DOE may authorize extensions of up to 3 months. Before issuing continuing awards, program Offices may request a statement from awardees that they are prepared to continue work on the project.

https://www.energy.gov/management/downloads/pf-2020-20-covid-19-guidance-financial-assistance-actions

DOI has stated that for awards it issues from its own funds, DOI is implementing the OMB Memorandum M-20-17.  Please see individual program announcements for deadlines.

DOI has stated that for awards it issues from DOD funds, DOI is implementing the DOD guidance to grantees (see below).

DOD Proposals: DOD recommends that program offices provide flexibility with upcoming proposal deadlines to the extent allowable under funding authorities. Some proposal deadlines may be extended by program offices, which will be posted within the opportunity on Grants.gov.  Otherwise, it will be up to PIs to individually request deadline extensions directly from the program officer.

DOD Awards:  Due dates of progress reports for currently active DOD awards (active as of 3/24/2020) may be submitted up to 3 months beyond the normal due date.  For any other deliverables related to research awards, contact the DOE program manager and/or grants manager.  No cost extensions should be supported by program offices in all possible cases; statutory funding limits will still apply.

DOD funds awarded under DOI awards should follow the DOD implementation.

https://basicresearch.defense.gov/COVID-19/Frequently-Asked-Questions/

CDMRP Proposals:  CDMRP has no plans to extend proposal deadlines as a result of COVID-19.

CDMRP Awards: (4/1/2020)  Awardees may delay submission of financial, performance and other reports on currently active awards for up to 3 months beyond the normal due date; contact the grants officer and grants officer's representative for extensions on other deliverables.

https://cdmrp.army.mil/about/covid-19/USAMRAA%20Supplemental%20Guidance%20on%20COVID-19_03.25.20.pdf

AFOSR Awards: AFOSR has recognized the potential need for no-cost-extensions for projects impacted by COVID-19.  For grants active as of 3/31/2020 and scheduled to expire prior or up to 12/31/2020, awardees may request a NCE of up to 12 months.  All requests must be submitted by OSR to the program officer and grants officer.  NCEs are not effective until Caltech receives a formal amendment to the award.

(4/1/2020)

ONR Proposals:  Deadlines are as stated in the opportunity.  PIs should contact the relevant program manager if they have questions about late submissions.

ONR Awards: ONR Research Performance Progress Reports are normally due 6/15/2020; reports submitted after this date will not be deemed late, but must be submitted by 8/15/2020.  For all grants scheduled to end between 3/31/2020 and December 31, 2020, ONR will issue a one year NCE; final reports for these awards will be within 120 day of the new end date.  For grants that ended prior to 3/31/2020 and with final report due dates after 3/19/2020, these reports may be submitted up to one year later.

https://www.onr.navy.mil/coronavirus

If you have any questions about information on this page, please contact Dick Seligman or David Mayo:

Dick Seligman, Associate Vice President for Research Administration
(richard.seligman@caltech.edu; x6073)

David Mayo, Director of Sponsored Research
(david.mayo@caltech.edu; x6219)