Armanino Blog

Administrative Relief for Federal Award Recipients Impacted by COVID-19

by Grant Lam
April 02, 2020

The Office of Management and Budget (OMB) has issued two memorandums (M-20-11 and M-20-17) to federal agencies that authorizes them to take certain actions as they deem appropriate with respect to the administrative provisions that apply to federal award recipients affected by COVID-19. The intent is to provide award recipients with short-term relief related to administration, financial management and audit requirements, without compromising federal financial assistance accountability requirements.

Allowability of Salaries and Other Project Activities

Federal agencies may allow organizations to continue charging salaries and benefits to currently active federal awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances). Federal agencies may also allow other costs to be charged to federal awards to the extent the costs are necessary to resume activities supported by the award, consistent with applicable federal cost principles and the benefit to the project.

It is also important to note that federal award recipients must continue to maintain appropriate records and cost documentation to substantiate the charging of any salaries and other project activities costs. During a period when the staff of many organizations are working from home, it may be challenging for certain organizations to maintain the level of documentation and follow the established policies and procedures they have been accustomed to and as required by the uniform guidance. Organizations may need to revisit and revise their policies and procedures to conform to a working from home environment.

Allowability of Costs Not Normally Chargeable to Awards

Organizations that 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, may be able to charge those costs to the federal award. It is important to note that organizations are required to maintain appropriate records and cost documentation to substantiate the costs.

Single Audit Extension

Organizations that have not yet filed their single audit with the Federal Audit Clearinghouse as of March 19, 2020 and have fiscal year ends through June 30, 2020 will receive a six-month extension beyond the normal due date. Organizations are not required to seek approval for the extension and organizations taking advantage of the extension would still qualify as a low-risk auditee. It is recommended that organizations maintain documentation of the reason for the delayed filing.

Additional Relief

Other provisions and relief provided by the OMB memo include the following:

  1. Flexibility with system for award management registration
  2. Flexibility with application deadlines
  3. Waiver for notice of funding opportunities (NOFOs) publication
  4. No-cost extensions on expiring awards
  5. Abbreviated non-competitive continuation requests
  6. Prior approval requirement waivers
  7. Exemption of certain procurement requirements
  8. Extension of financial, performance and other reporting
  9. Extension of currently approved indirect cost rates
  10. Extension of closeout

For more information on federal and state regulations and relief during COVID-19, visit the Armanino Resource Center.

April 02, 2020

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Grant Lam - Partner, Audit - San Francisco CA
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