Frequent Questions about Grants and Coronavirus (COVID-19)
The Office of Management and Budget (OMB) has issued a new memorandum that provides disaster relief flexibilities to reduce burden for financial assistance. OMB Memorandum M-21-20 (March 19, 2021 OMB Guidance) allows Federal awarding agencies the authority to grant exceptions to recipients affected by the COVID-19 pandemic as they deem appropriate and to the extent permitted by law. The exceptions not only apply to recipients with COVID-19 related Federal financial assistance awards, but also to recipients with assistance awards not related to COVID-19. Accordingly, the Office of Grants and Debarment (OGD) has updated these Frequent Questions (FQs) to supplement the March 19, 2021 OMB Guidance and to provide information to applicants for, and recipients of, EPA grants and cooperative agreements relating to the impacts of COVID-19.
The earlier flexibilities provided in previous OMB memoranda have expired. To review these previous OMB memoranda, see:
- OMB Memorandum M-20-11 (March 9, 2020 OMB Guidance) (PDF)
- OMB Memoranda M-20-17 (March 19, 2020 OMB Guidance) (PDF); M-20-20 (April 9, 2020 OMB Guidance) (PDF)
- Memorandum M-20-26 (June 18, 2020 OMB Guidance) (PDF).
Note: For the purposes of these FQs, the term “grant” also includes cooperative agreements.
View all frequent questions related to grants and cooperative agreements and Coronavirus (COVID-19) below.
- Grant procedures
- Allowable costs
- Disruption of operations
- Grant competitions
- Suspension and debarment
- If an EPA grant recipient permits their employees administrative leave to comply with social distancing guidance from public officials, are the costs allowable?
- Due to the increased demands for assistance in processing unemployment claims, testing for COVID-19, and similar responses to the public health emergency, state, tribal or local governments may seek to re-assign employees working on EPA-funded grants to those projects. Can these recipients continue to charge the costs for compensating the employees to their EPA-funded grants when the employees are performing work unrelated to the EPA grants?
- If an EPA grant recipient is forced to lay off employees due to COVID-19 related project terminations, are the costs for severance packages allowable?
- How would a program participant or recipient employee recoup incurred expenses associated with cancellation if the participant or employee must cancel travel to a meeting or other event either because the event was cancelled, flights were cancelled, or the participant or employee is affected by COVID-19?
- Does EPA require recipients to cancel events due to the COVID-19 public health emergency?
- Are unanticipated costs associated with recipient employees teleworking due to COVID-19 social distancing requirements and/or state-local stay at home orders allowable?
Disruption of Operations
- Will EPA provide a waiver to the performance period limitations in section 10 of Grants Policy Issuance 11-01 (GPI 11-01), Managing Unliquidated Obligations and Ensuring Progress under EPA Assistance Agreements, for assistance agreements impacted by COVID-19?
- How will the Agency handle partial terminations/deobligation of funds for projects or portions of projects that cannot be rescheduled?
- Will there be any ability to reprogram or redirect federal funds or change the nature of the activities to be performed under a grant based on emergency needs or inability to conduct certain tasks?
- Are there legal limits on the amount of time EPA can extend the length of periods of performance of a grant if we cannot perform it within the original period of performance?
- As a general matter, how can states avoid losing funds already received for projects that might be delayed?
- What about grants to local governments, non-profits and institutions of higher education-how are they funded?
- Do regulatory exceptions, waivers and other forms of COVID-19 related relief for EPA grants to pass-through entities (also known as “prime recipients”) extend to their subrecipients?
- Can EPA waive “match” or cost share requirements if a recipient is unable to meet the requirement due to budget shortfalls as a result of COVID-19?
- Are recipients allowed to use third-party virtual platforms to perform work under EPA assistance agreements?
- Can recipients change the activities in the scope of work for competitive grants?
- What is EPA doing to accommodate challenges applicants experience in preparing applications due to COVID-19?
- Can applicants submit their applications outside of Grants.gov due to the challenges associated with COVID-19?
- How will issues or delays recipients are experiencing with performance issues under their grants affect how they are evaluated on past performance evaluation criteria under future competitions?
Suspension and Debarment
- Is the Agency still issuing notices of suspension, notices of proposed debarment, or taking other suspension and debarment (S&D) actions?
- Will the Agency still issue suspension and debarment (S&D) decisions upon completion of contest proceedings?
- How may respondents of a suspension and debarment (S&D) notice contest a notice of suspension, notice of proposed debarment, or show-cause notice?
- Will exclusion records on the System for Award Management (SAM.gov) be maintained and updated during COVID-19 operations?