Important COVID Updates – Salaries, Documentation, New Awards and Communications
May 11, 2020
Memo to Principal Investigators and Research Administrators,
The purpose of this memo is to update researchers and administrators on requirements for awards that have been impacted by the COVID-19 emergency. The Office of Management & Budget (OMB) released guidance on March 19th allowing a number of flexibilities for the research community including the allocation of idle time to research awards. OMB will be reassessing their guidance to federal agencies by June 17th. The current Boston University policy allows charges on federal awards for idle time through June 1st. Under federal guidance and BU policy, we have a responsibility to maintain adequate documentation of research/programmatic progress, personnel effort, and other project costs or delays impacted by the pandemic. This information will be needed to support your research program for several reasons:
- Documenting and quantifying the impact of COVID-19 will be important when supplemental funding may be made available by a sponsor. We stand a greater chance of receiving supplemental funding if we have documented evidence supporting the impact.
- Our compliance obligations for sponsoring agencies are requiring documentation of salary charges when work in support of a project is not possible (idle time). Additionally, Federal sponsors, including NIH (FAQ dated April 13, 2020), have issued instructions regarding funder notification about any other impacts, such as changes to project scope, personnel, or unforeseen costs, as a result of the COVID emergency.
Documentation
Idle time (sometimes referred to as non-productive time) refers to the time an employee would have spent on their research had COVID-19 not caused disruptions to campus operations. While idle time has been allowable on most federal awards since the release of OMB’s guidance it was only recently that documentation requirements related to this time were made available. To assist with the documentation of idle time, Post Award Financial Operations (PAFO) will be distributing worksheets via SharePoint to Department Administrators and Researchers to indicate where idle time should be noted due to disruptions of COVID-19. These worksheets will show the percentage allocation of salary for employees on grants for the prior periods (March and April) as recorded in our systems. Further instructions will follow under separate cover with the SharePoint site link.
Summer Salary
Our Awarding Agencies have yet to release firm guidance regarding summer salary. Based on existing guidance and through discussions with our peer institutions we do not believe that awarding agencies will reimburse compensation for 9-month faculty researchers whose research is idle for periods during the summer due to COVID-19 disruptions. We expect that awarding agencies will continue to reimburse compensation for researchers who are working remotely and those that can continue research on campus.
New Awards
The OMB guidance released on March 19 states that “Awarding agencies may allow recipients to continue to charge salaries and benefits to currently active Federal awards …” therefore idle time will likely be unallowable expenses on new awards. For example, NIH FAQs explicitly state “Recipients may not initiate charges for salaries and benefits on new awards where the work has not yet started”. This decision may vary across sponsors.
If you receive a new award and have questions about how to proceed, please reach out to your SP RA to discuss. We are currently processing all new awards. If your ability to carry out the work is severely impacted we may let the sponsor know you cannot begin the work now, and share your plan on resumption.
Communications with Sponsors
During this time, any communications to your Program Officer should be shared with SP. If you are proposing a supplement, change in scope or budget, or prior approval requests, they should first be reviewed by your Sponsored Programs Research Administrator. Generally, those requests are authorized by SP and shared with your Grants Management Official at the Sponsor by SP. While sponsors have documented flexibilities on requirements for projects impacted by the COVID crisis, please remember prior approval requirements still exist for active awards and awards with effort requirements (such as NIH Career Development awards). Also, if your research is funded under a federal contract, the flexibilities under the OMB guidance on March 19th may not apply. You are also required to inform your funder about any impacts (programmatic or financial) on the contracted work. Please reach out to your SP RA should you have any questions.
If you receive any communications from your Sponsor or Program Officer, please be sure to share it with Sponsored Programs (ospera@bu.edu).
We continue to regularly update the Research COVID website. We recommend that you check this resource weekly for further guidance. Please reach out to us with your questions
Sincerely,
Diane Baldwin – Associate Vice President, Sponsored Programs (dbaldwin@bu.edu)
Renna Lilly – Assistant Vice President, Sponsored Programs (rolilly@bu.edu)
Andrew Soares White – Vice President, Financial Operations (asoares@bu.edu)
Gretchen Hartigan – Assistant Vice President, Post Award Financial Operations (hartigan@bu.edu)