Frequent Questions about Grants and Coronavirus (COVID-19)
In response to the COVID-19 crisis, the Office of Management and Budget (OMB) issued three memoranda providing class exceptions allowing Federal awarding agencies to grant various administrative, financial and audit requirement flexibilities to their applicants and recipients.OMB Memorandum M-20-11 (March 9, 2020 OMB Guidance) (PDF) was narrow in scope and only applied where the Federal agency determined that the purpose of their awards was to support continued research and services necessary to carry out the emergency response related to COVID-19 and did not directly apply to EPA awards. The other two memoranda, OMB Memoranda M-20-17 (March 19, 2020 OMB Guidance) (PDF) and M-20-20 (April 9, 2020 OMB Guidance) (PDF), were applicable to EPA awards. Accordingly, the Office of Grants and Debarment (OGD) developed these FQs to supplement the March 19, 2020 OMB Guidance and April 9, 2020 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 flexibilities provided in the OMB memoranda were time limited. As such, on June 18, 2020, OMB issued Memorandum M-20-26 (June 18, 2020 OMB Guidance) (PDF) which provided notification that most of the flexibilities in the March 19, 2020 OMB Guidance and April 9, 2020 OMB Guidance expired as scheduled on June 16, 2020. However, recognizing the uncertainty of the re-opening phase and the speed of the ramp-up effort, the June 18, 2020 OMB Guidance provides an extension of the following two flexibilities: Item 1, Allowability of salaries and other project activities (item 6 in the March 19, 2020 OMB Guidance) through September 30, 2020; and Item 2, Extension of Single Audit submission (item 13 in the March 19, 2020 OMB Guidance) through December 31, 2020. In addition, OMB added restrictions to the flexibilities allowed in item 1, Allowability of salaries and other project activities.
Now that the March 19, 2020 OMB Guidance and April 9, 2020 OMB Guidance are partially rescinded, OGD has updated the FQs to reflect the rescission and the changes described in the June 18, 2020 OMB Guidance.
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
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?
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?
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?