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DOD shares guidance to Proposers & Awardees Impacted by COVID-19

Mar 24, 2020, 13:09 PM by Melodi Moore
A Dear Colleague letter from the Department of Defense Research Directorate today answered questions that many involved in DOD research have asked or need to know.  They are just one of multiple sponsors who are offering greater flexibility in grants management during this national health emergency. Questions include:

Q: Will I have to meet the current deadlines for reports and other deliverables related to my research award?

A: Consistent with OMB Memorandum M-20-17, the 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. 

Q: Can I continue to charge salaries and benefits to currently-active awards for personnel who would normally be paid out of the award (e.g., graduate students, principal investigators, and postdoctoral researchers)?

A: Based on OMB Memorandum M-20-17 and the uniform guidance (2 CFR 200.403, 2 CFR 200.404, 2 CFR 200.405), the DOD will allow recipients to continue to charge salaries and benefits to currently-active awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal.  DOD components may allow other costs to be charged to federal awards necessary to continue work on a project even if in a period where primary research activities are limited or curtailed.  To the maximum extent practicable, recipients will be expected to invoke or institute any and all reasonable mitigation actions and practices to lessen the cost to the government during the crisis period.  Such actions may be part of an existing program created by the recipient or may be created to respond to this crisis.  Appropriate records and cost documentation must continue to be updated and maintained as required by 2 CFR 200.302 - Financial management and 2 CFR 200.333 - Retention requirement of records.

Q: COVID-19 closures have delayed my work. Can I receive a no-cost extension on my active award?

A: It is DOD policy that no-cost extensions must be supported in all possible cases.  However, please be aware that funding expiration statutes may prohibit extensions.  Please contact the DOD grants manager for award-specific guidance. 

Q: There are upcoming application deadlines for a program I want to submit a proposal for. Can these be extended?

A: The DOD recommends 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. Proposers are encouraged to monitor to see if an extension has been posted.

There are a few more questions included.  If you have a DOD award and have more questions, the best thing to do is contact your program contact at DOD.  If you do not know who that is, please contact your pre-award analyst and they can assist you in finding the answers.