Research Policy Analysis and Coordination
Frequently Asked Questions
Extramural sponsors and UC have issued various guidance and policies related to the impacts of COVID-19 on sponsored projects.
This set of Frequently Asked Questions was developed in collaboration with the ten UC campuses. This is a living document that will evolve and be revised as we hear from sponsors and receive further policy and guidance updates from UC leadership.
1. I was approached by a sponsor/foundation wishing to provide me with funds to conduct research relating to COVID-19. What should I do?
Conducting any sponsored activity requires multiple offices to review and negotiate the terms of the sponsored award and to assist you in obtaining required institutional approvals (e.g., IRB, IBC, etc.). You should immediately contact the appropriate research administrator at your campus who can assist you with an institutionally-compliant proposal submission, including indirect cost recovery.
Prior Approvals, Allowability of Costs, and Effort on Sponsored Projects
2. My project is running out of funds, but I still have scope of work to complete and costs to be paid. What should I do?Some federal-funding agencies are providing supplemental funding to help mitigate the disruption cause by the COVID-19 pandemic. Universities and higher education associations are advocating for targeted funding to support awards impacted by the disruption. The funding situation will likely rapidly change in the next few months.
When you are facing an immediate funding challenge, contact your agency program managers as soon as possible, by phone and in writing, to ensure they are fully aware of your situation. If your agency program manager is supportive of a request for supplemental funding, please contact your Contract and Grant Officer for the next steps.
3. I have overspent on my grant and my sponsor will not provide supplemental funding, what do I do?
If you overspend on your grant:
- You will have to use your discretionary funds to pay the overage.
- If you run out of discretionary funds, your department will have to pay the remainder.
- If your department runs out of discretionary funds, your division will have to pay the remainder.
4. I’m a PI working remotely from home during self-isolation. Can my effort still be charged to the grant?In general, yes, provided you remain engaged in your project. Current sponsor prior approval requirements regarding disengagement and effort reductions remain in effect.
5. Can my salary still be charged to the grant if I am home sick and can't work on my project?
Yes. Pursuant to the university’s indirect cost rate agreement with the federal government, sick leave and other paid absences that are permitted under university policy are claimed on federal awards as part of the normal cost of salaries and wages.NIH provided guidance that allows institutions affected by COVID-19 to continue providing stipend payments to fellows and trainees who may be unable to work as a result of or related to COVID-19. Please work with your Contract and Grant Officer to notify the assigned NIH grants management official, and provide documentation demonstrating the effect of COVID-19, and how long the institution will be affected.
6. UC campuses have implemented a hiring freeze. I was just informed that I have received a new award. May I start charging researchers’ salaries to the award?Yes, under certain circumstances. New hires on contract and grant funds are exempt a funding freeze unless the Pl knows that no work can be realistically performed remotely or the sponsor will not remote work or paid leave in lieu of remote work. Contact the sponsor for clarification. PIs are responsible for covering the cost of their research team and cannot expect campus funds to cover shortfalls or disallowed costs.
7. What if I am home due to childcare or being directed to not come into work and can't work on my project from home? Can my paid administrative leave per UC President Executive Order still be paid for by my grant?
The Office of Management and Budget has issued a series of memorandum authorizing federal grant-making agencies administrative flexibilities to allow for COVID-19-related reimbursements, such as allowing administrative leave to be charged against federal grants during the current COVID-19 crisis. As such, this paid administrative leave is an allowable cost could be charged to federal grants and contracts consistent with other employee benefits.
UC asserts and Federal agencies have confirmed that charging administrative leave to currently active awards as it is consistent with UC’s policy of paying salaries under unexpected or extraordinary circumstances.
The most common federal funders, including the National Institutes of Health (NIH), the National Science Foundation (NSF), and the Department of Defense (DOD), have implemented guidance to allowing the administrative flexibilities contemplated in OMB’s guidance.
Many non-profit and foundation sponsors have issued guidance providing for similar administrative flexibilities as federal agencies.
In the event that your sponsor does not afford such flexibility, these costs should be removed.
8. If the agency program officer or grants officer is unavailable (or if the agency is closed) due to COVID-19, can grant personnel continue to work and charge salary to the project?
In most cases, grantees should be able to continue work until their period of performance and funding is exhausted. Contact your sponsored project office for further information.
9. I have a federally-subaward through a pass-through-entity, such as the State of California or a foundation. May I assume that administrative flexibilities apply to my award?
You cannot assume that your award has been provided administrative flexibilities. You should reach out to the immediate sponsor for assistance. If you believe that your award should benefit from administrative flexibilities, contact your Contract and Grant/Sponsored Projects Office. They may coordinate with RPAC to reach out to the sponsor to discuss the situation.
Research studies with a lab component that uses Personal Protective Equipment (PPE).
10. To ensure safety in my lab during this period, who pays for other supplies (masks, wipes, etc.) ?
Personal protective equipment needed to perform a grant can be a direct charge. Supplies needed for cleaning should be covered by a non-grant account.
11. Can PPE in my lab be donated to support COVID-19 healthcare workers?
OMB has issued guidance that provides flexibility to federal agencies in allowing PPE to be reallocated for a healthcare use. Prior to donating any PPE in your lab, consult with your campus.
COVID-19 Related Expenses
12. Should I be tracking COVID-19-related costs, including PPE?
This is an unusual time in which unforeseen costs have emerged. UC may be able to recover these costs through special funding from the federal government. The Office of the President asks that investigators carefully track these expenses.
13. I am a PI/researcher and I am required to work from home as a result of the coronavirus. Would I be able to charge supplies relating to telework (i.e., laptop, printer, office supplies) to my grant?
These types of expenses are considered administrative costs (indirect costs), and generally are not appropriate as a direct cost unless specifically approved by the sponsor. Consult with our supervisor about your needs in order to be set up to work from home.
14. If I have a grant, whom should I contact if my project activities are impacted by COVID-19
PIs remain responsible for conducting their research in a safe and secure manner. University leadership is providing resources and assistance to aid PIs as they make decisions regarding their research. Accordingly, if project activities are impacted, PIs should contact their immediate supervisor, unit leadership (chair, dean, ORU director), central offices (particularly OR, IRB, IACUC, IBC, OCV, EH&S, etc.), collaborators or sponsors as they feel appropriate.
15. Will a grant sponsor provide an extension to my grant award if the planned activities are disrupted by COVID-19?Many sponsors allow for one-year, grantee-approved, no-cost extensions at the end of a project’s performance period. If your sponsor does not provide this pre-approval, please contact your unit’s grants administrator to determine how to make a request to the sponsor.
16. Will a grant sponsor provide flexibility on prior approval requirements for administrative actions as a result of COVID-19 such as carryover of an unobligated balance?Yes, many sponsors have expressed that they will be flexible with prior approval requirements for administrative changes to a grant. For example, NIH stated on a call that prior approval will not be required for the carryover of an obligated balance.
17. What proactive efforts should I be undertaking for a project impacted by COVID-19 that is funded via a contract (as opposed to a grant) (e.g., industry, non-profit, federal, service, etc.)?
The principal purpose of a contract is to acquire research services for the direct benefit or use of the other party – they are not as flexible as grants.
Be proactive in your engagement with your scientific counterparts at the sponsor to help them understand whether any/all work can proceed, and to discuss scope or financial impacts. Please involve your Contract and Grant Officer in any conversations with Contract Officers at the sponsors and formal prior approval requests or no cost extensions. If you are unsure if your project is funded by a grant or contract, please contact your Contract and Grant Officer.
Proposal and Report Deadlines Impacted by COVID-19
18. I am self-isolated, quarantined, and/or at home caring for a sick family member and am unable to submit my grant application by the stated deadline. May I request an extension?Most federal agencies do not grant prior approval for late submissions; however, there are existing policies that address extenuating circumstances. We strongly encourage you to discuss your specific situation with both your agency program officer and your sponsored project contact.
- NIH: You may be able to submit a grant proposal after the deadline. Read NIH LATE APPLICATION POLICY Due to Public Health Emergency for United States for 2019 Novel Coronavirus (COVID-19) (NOT-OD-20-082)for details.
- NSF: You may be able to submit a grant proposal after the deadline. Read FAQ #16 “Can I receive an extension to the deadline?" for details. NSF has extended the deadline dates for specific funding opportunities. A listing of these extensions is available on NSF's COVID-19 webpage.
- DOD: Recommended that program offices provide flexibility with upcoming proposal deadlines to the extent allowable by funding authorities and by the need to have enough time for merit review of submitted proposals. Please contact the program officer and grants manager for the funding opportunity in question to seek an application deadline extension. Read: Frequently Asked Questions for DOD Research Proposers and Awardees Impacted by the Novel Coronavirus
- DOE: Deadlines for submitting pre-applications, letters of intent, or applications may be extended by no more than fourteen (14) days from the applicable due date. Please contact the Program Manager identified in the FOA or DOE Laboratory Announcement under which the pre-application, letter of intent, or application is being submitted prior to the applicable due date. Read: DOE Memorandum for Applicants and Awardees
19. Will a grant sponsor provide flexibility on late reports due to COVID-19?
Possibly. During these extraordinary times, many sponsors are permitting administrative flexibility. It is always best to consult your sponsor before the original due date of any reporting.
- NIH will allow recipients that are affected by COVID-19 to delay submission of financial, performance and other reports required by the terms and conditions of the grant award, provided proper notice about the reporting delay is given by the recipient to NIH. NIH will accept these late reports, but will delay issuing any continuing grant awards until the reports are received and accepted.
- NSF has automatically extended the due date for submission of all annual project reports due between March 1 and April 30, 2020, by 30 days. These project reports must continue to be submitted via Research.gov. PIs are reminded that NSF cannot make any new award or supplement any existing award, if the PI(s) or any co-PI(s) has an overdue annual project report; therefore, it is vital that annual reports are submitted by the revised due date.
- NSF has automatically extended the due date for submission of all final project reports and Project Outcomes Reports due between March 1 and April 30, 2020, by 30 days. These final reports must continue to be submitted via Research.gov. Recipients are reminded that NSF cannot make any new award or supplement any existing award if the PI or any co-PI(s)s has an overdue final report; therefore, it is vital that final reports be submitted by the revised due date.
- DOD will allow grantees to delay submission of financial, performance and other reports on currently-active award accounts up to three months beyond the normal due date. For any other deliverables related to research awards, please contact the DOD grants manager and/or program manager for award specific guidance.
- DOE guidance states that progress reports for grants, cooperative agreements, and interagency awards may be submitted through the PAMS website at https://pamspublic.science.energy.gov as soon as practicable. Note that delays in submitting progress reports may cause unavoidable delays in continuation funding.