COVID-19 Research FAQs: Continuing Obligations
Q: Will NIH accept late progress reports and financial reports where delays are due to the effects of COVID-19?
NIH issued Guide Notice NOT -OD – 20-086 on March 12: If you are unable to complete and submit a financial and RPPR by the scheduled due date, due to the effects of COVID-19, please contact your SP RA for late progress reports and/or PAFO RA or PAFO Manager for late financial reports, who will contact the assigned grants management and/or program official to let them know the reports will be late.
Note in NIH Guide Notice NOT-OD-20-083, the following guidance has been issued on progress reports (subject to change and institutions are encouraged to check for any updates directly from NIH as they become available): Per NIH Grants Policy Statement sections 8.4.1 and 8.6, as well as the terms and conditions outlined in Notice of Award, NIH requires that recipients periodically submit financial and progress reports. NIH understands that some reporting delays due to the impact of coronavirus may be unavoidable. Therefore, if recipients are unable to complete and submit a progress report ((Research Performance Progress Reports (RPPR)), Financial reports (Federal Financial Report expenditure data), and/or invention report by the scheduled due date, they should promptly contact the assigned grants management and/or program official. Although NIH will accept these late reports, grant awards will be delayed until the required reports are submitted and accepted by NIH.
Q: Late applications and solicitations where coronavirus (COVID-19) will adversely affect some applicants’ and recipients’ ability to submit applications in a timely manner.
NIH: When delays occur because the applicant or recipient organization is officially closed or unable to submit grant applications due to the effects of COVID-19, the NIH will consider accepting applications late, on a case-by-case basis, in accordance with the NIH Grants Policy Statement, Section 2.3.9, under the following circumstances:
Institutions must submit applications or reports as soon as possible after reopening or resuming operations so that grant applications can be submitted, not to exceed the number of days the institution was officially closed or unable to submit grant applications.
Institutions must submit a cover letter with the applications with enough detail about the delay so that NIH staff can make a determination whether circumstances justify accepting the application late.
Institutions need not request advance permission to submit late due to this declared emergency.
NIH will be issuing additional guidance related to this public health emergency in the near future.
DOJ: Solicitations with application due dates between March 16th and March 31st will have a 2-week extension for submission. OJP program offices are in the process of updating those due dates now. OJP will continue to monitor the situation and determine if additional adjustments to closing dates will be needed. Grants.gov and OJP’s Grants Management System remain open to continue to accept applications.
CDMRP ALSRP, ARP and OCRP: Due to impacts of COVID-19, the Amyotrophic Lateral Sclerosis Research Program (ALSRP), Autism Research Program (ARP), and Ovarian Cancer Research Program (OCRP) have extended the pre-application submission deadline. The extension is for all applicants.
Requests for further extensions to the new pre-application submission deadlines will not be accepted. The FY20 ALSRP released funding opportunities on January 17, 2020. The FY20 ARP and FY20 OCRP released funding opportunities on February 27, 2020.
Please consult the modified Program Announcements available on Grants.gov and contact the CDMRP Helpdesk with any questions (help@ebrap.org)
STScI, NASA, ESA, and CSA have decided to delay the proposal deadline for JWST Cycle 1 GO proposals to no earlier than May 27th, 2020. We are continuing to monitor the situation and will provide an update on the schedule on April 15th, 2020.
Please contact the jwst helpdesk if you have any questions.
Q: Where a research project has a strict timeline, we are concerned about a possible failure to perform within the agreed-upon statement of work. This failure may be due to a slow down or gap in activities, particularly where staff may need to work from home.
Clearly, this is an extraordinary situation. If the scope of work demands a precise schedule in order to make an experiment viable, then the investigator should recognize and document instances where that schedule was unable to be met and the data resulting from that experiment may not be able to be used (or can only be used with certain cautions). If it is not the case that such precision is required for scientific reliability but rather needed for good business practices or to meet an agreed-upon sponsored project schedule, then it is anticipated that agencies will recognize the unique circumstance and be flexible if they can, including granting no-cost time extensions if needed. The investigator should reach out to the program officer as soon as a delay is anticipated.
Note that this applies to grants. For contracts requiring deliverables by a certain date, it may be possible to invoke the Excusable Delays clause. In any case, contractors should confer with their contracting officer about appropriate next steps as soon as a delay is anticipated. Council of Governmental Relations (COGR) recommends that investigators actively document their specific situations to provide a basis for any adjustments that may need to be requested when business returns to “normal” as well as the specific terms of an individual contract that may address this type of situation.
Q: Will agencies consider longer no-cost time extensions if they are needed to finish a project after disruption?
Researchers should document the actual impact of COVID-19 on the progress of their grants to provide substantiation for any future no-cost time extension request. It is not known at this time if agencies will consider longer-than-normal no-cost time extensions or multiple no-cost time extensions in this situation, but no-cost time extensions covered under expanded authorities will still be available for federal awards.
NIHNational Institutes of Health: The NIH Standard Terms of Award provide the recipient the authority to extend the final budget period of a previously approved project period one time for a period of up to 12 months beyond the original completion date down in the NoA. Any additional project period extension beyond the initial extension of up to 12 months requires NIH prior approval.
NSF: grants are eligible for a one-year grantee-approved no-cost extension and then further extensions as approved by NSF. If you foresee a need for NSF-approved extensions, you should include that information in your annual report and discuss the need ahead of time with the cognizant NSF program officer for your award. See the Proposal & Award Policies & Procedures Guide (PAPPG), Chapter VI.D.3, for additional information.
DOJ: In accordance with Part 200 Uniform Requirements (2 C.F.R. Part 200, as adopted by DOJ) and consistent with the DOJ Grants Financial Guide, most OJP awards may be eligible for one no-cost extension of up to 12 months. If the grant has previously received a no-cost extension and an additional extension will be requested due to the extenuating circumstances, refer to the DOJ Grants Financial Guide for additional information and consult with your grant manager as needed.
Please note that awards funded by the Office for Victims of Crime (OVC) (or any other OJP bureau/program office) under the provisions of the Victims of Crime Act (VOCA) of 1984, are available during the federal fiscal year of the award, plus the following three fiscal years. OVC and other OJP bureaus/program offices have no discretion to permit extensions of any award’s period of performance beyond the statutory period.
Q: I can’t get to my research site and my research will be severely impacted. Will the sponsor provide incremental funding and/or additional time so that I can successfully complete the aims of the award?
We expect federal agencies will recognize the difficulties inherent in this situation and work with institutions to facilitate the conduct of the project. As a reminder, Faculty should reach out to their SP RA to discuss, if appropriate the SP RA will (1) inform their program officer and grants officer that prior approval is required if the need arises for additional Federal funds to complete the project (200.308.(c)(1)(viii)) and (2) notify the federal agency as soon as “problems, delays, or adverse conditions which will materially impact the ability to meet the objective of the Federal award” (200.328.(d)(1)) are known.
In the latter case, the notification must include a statement of the action taken or contemplated and any assistance needed to resolve the situation. It is possible that there will not be an immediate answer on what is needed to resolve the situation; in that case, recipients should simply indicate that they will report back when more is known.
Per NIH FAQs on NOT-OD-20-086: NIH understands that travel restriction may continue to occur through the remainder of the public health emergency and will likely affect the progress of NIH-funded research. Recipients must contact the funding IC to alert them of the delays. NIH is committed to working with its applicants and recipients during this public health emergency.