UW Research

June 26, 2020

NIH & NSF Adopt Flexibility from OMB Memo M-20-26

NIH and NSF have coordinated on their implementation of the flexibilities from OMB Memo M-20-26. This memo gives agencies the authority to extend certain flexibilities to award recipients affected by COVID-19.

Please refer to the PAFC COVID website for more information on the OMB Memos.

These flexibilities are:

Salary & Other Costs

Charging salaries and fringe benefits to active (not new) awards consistent with awardee (UW) policy regarding paying salaries under unexpected or extraordinary circumstances.

Charging other costs to active (not new) awards necessary to resume activities supported by the award, consistent with cost principles and the benefit to the project.

To take advantage of these flexibilities:

  • Document that other sources have been exhausted
  • Maintain records and cost documentation to substantiate the cost
  • Implement necessary steps to save overall operational costs and document those steps

There is no guarantee supplemental funding will be available to cover any shortage of funds to additional costs incurred on the award due to COVID disruption.

Single Audit

Extension of Single Audit Submission and COVID-19 Emergency Acts Fund Reporting: This flexibility impacts central UW processes. There is no specific action that needs to be taken by PIs or departments related to this extended flexibility.

Rescinded Flexibilities

As mentioned 6.23.2020, other flexibilities granted through OMB Memo M-20-17 and M-20-20 are rescinded, effective June 17th. Please refer to the PAFC COVID website for more information.

  • Donations: Donating supplies purchased on an award to support COVID-19 efforts requires sponsor authorization. If this is a need, submit a request to the sponsor, using OSP guidance.
  • Prior Approvals: While certain prior approval requirements were waived, as of June 17th, those waivers are now rescinded. Refer to your award and if the sponsor requires prior approval, review Prior Approval Steps from OSP.

NOTE: Flexibilities implemented by NIH and NSF on awards made for carrying out emergency response to COVID-19 are in place until July 26th (OMB Memo M-20-11).