COVID-19 Research FAQs: Salary
Q: What do I need to know about COVID disruptions to work and “idle time”?
Refer to this May 11, 2020 Memo about idle time documentation and funding.
Q: How do I submit Personnel Activity Reports (PARs) while working remotely?
The PAR deadline is Friday, April 10th. We always accept electronic signatures but starting Thursday, March 12th through Friday, April 10th, we will also accept approval via email from the BU Employee directly or from the PI/Supervisor on behalf of any non-faculty or Student BU employee. This will assist individuals who work remotely and do not have access to scanners and/or electronic signatures. Please note that the percentages on the PAR must be filled out and total to 100%.
Please ensure all PARs are sent to us via our email box: effort@bu.edu
Q: What do we do if Research Staff are unable to work in the Lab and are paid from Sponsored Funds?
Decisions on salary allocation on Sponsored Funds for individuals unable to work is ultimately up to the awarding agency. BU is monitoring and communicating with Sponsors and while we have heard from our most prominent Sponsors, we have not heard from every Agency. The below information is provided as guidance with specific sponsor information.
Per Boston University policy, if an employee is paid from Sponsored Funds, regardless of on or off site, and is either using sick, vacation, or FMLA time during this period of COVID-19, the Sponsored Project should continue to be charged.
If a BU employee (staff, faculty, or PhD track student) is healthy but is considered non-essential personnel and therefore, due to reductions in research in response to COVID-19, is unable to perform their job duties in BU Labs/space or off-site, their salary should continue to be allocated to the Sponsored Award at the same effort distribution work was assigned. We are continuing to reach out to specific sponsors to determine their approach during this crisis and will continue to update this FAQ. Please see below for links to guidance from our largest Awarding Agencies and the Office of Management and Budget (OMB). Please contact your PAFO Research Administrator for specific questions.
For BU undergraduate and graduate students (not including PhD track students) that are unable to work due to restrictions in research activity due to COVID-19 (including an inability to work remotely), the Student Employment Office has released guidance that students will be furloughed and paid either two weeks of continuation pay or, if you are a Work Study student, the balance of their Work-Study award in one lump sum.
OMB
Notice M-20-17 entitled “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations.” The memo noted “Awarding agencies may allow recipients to continue to charge salaries and benefits to currently active Federal awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Awarding agencies may allow other costs to be charged to Federal awards necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project.”
Sponsor Guidance
Individual sponsor guidance is being maintained at Research Support’s website at https://www.bu.edu/research/2020/03/24/sponsor-guidance-and-agency-responses-to-covid-19/
Q: On March 15, the State Department issued a travel advisory raising all countries outside of the U.S. to a Level – 3 “Reconsider Travel” status. If researchers choose to travel abroad (e.g., to fulfill a grant responsibility such as present a paper or attend a meeting to discuss research) although their institution has advised against travel to that country, can salary still be charged to the award – even if they need to stay in the country longer than originally anticipated?
Travelers should follow BU policy. If such travel is critical, obtain an exception in advance. BU has issued a memo regarding travel which can be found here.
Q: Can salary continue to be charged if a researcher is on multi-day self-isolation period? Does it matter if the researcher is able to continue to work on the project from the self-isolation site (e.g. home or designated facility) or is unable to work (e.g., because the work must be done in a wet lab or field site?). Does it matter whether the self-isolation is self-imposed, institution-imposed, or government-imposed?
If the traveler is following BU-imposed or government-imposed self-isolation requirements, salary support will be continued as allowed under BU’s policy. Federal agencies have not yet issued guidance on this particular topic so you must be able to identify these transactions if federal guidance determines such costs are unallowable. Sick time, vacation time and/or paid administrative leave may be taken if permitted by BU’s policy. If the researcher is able to work from home, Q.1 under Remote Work Environments should apply.
Q: If schools or elder-care facilities close, can award-funded employees stay at home to do child-care and eldercare and still charge their salary to a grant?
If an award-funded employee stays home due to a school or facility closure for child or elder care needs, the employee’s salary would be charged in accordance with BU leave policy. As provided for in 2 CFR 200.431 Compensation – Fringe Benefits (a), the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, non-Federal entity-employee agreement, or an established policy of the non-Federal entity.
Please note that this may not be allowed under all Sponsors.
Q: 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?
Grantees should be able to continue work until their period of performance and funding is exhausted. If prior approvals are required, Sponsored Programs will continue to submit their request to the funding agency electronically. If approval is not forthcoming, Sponsored Programs will consult with the PI on whether to proceed with the action for which approval was requested, understanding that any costs associated with that change may need to be absorbed by the department if approval is not subsequently granted.
For cooperative agreements and contracts that require agreement or contracting officer approval, the risk is likely to be higher. If some projects may not be able to proceed fully or at all, document the situation where work needed to slowdown or stop to help guide agency approval requests (time extensions, supplemental funding) once work resumes.
DOJ: Grantees (and subrecipients/subgrantees) should review the DOJ Grants Financial Guide and the Part 200 Uniform Requirements (2 C.F.R. Part 200, as adopted by DOJ) (see, for example, 2 CFR 200.430 and 2 C.F.R. 200.431, under Subpart E – Cost Principles), and BU (or subrecipient’s/subgrantee’s) established policies, to help determine how the grantee’s personnel costs may be treated during any interruptions to the work under the award. Direct any questions about allowable costs to your OJP grant manager, or to OJP’s Office of the Chief Financial Officer by calling the Customer Service Center at 1-800-458-0786 (TTY: 202-616-3867), or via email at ask.ocfo@usdoj.gov.