UW Research

March 26, 2020

NSF: Response to OMB Memo M-20-17 – Flexibility related to COVID-19

Last week the Office of Management and Budget (OMB) issued Memorandum (M-20-17), a guideline for Federal Agencies to provide, at the individual agencies discretion, administrative relief due to COVID-19 related impacts.

On March 23, 2020, NSF issued guidance based on the OMB memo. This guidance covers a broad range of administrative topics that are the responsibility of different UW departments. We’ve included a brief summary of each topic.

Award Expenditures

Allowability of Salaries and Other Project Activities

Salaries:

The UW does not currently have a policy about charging salaries under “unexpected or extraordinary circumstances”, so there is no change to the way salaries are allocated to NSF awards. UW central offices are reviewing this policy; any changes will be posted on the PAFC website.

Other Project Activities:

Follow NSF guidance. NSF has not made any guarantees of supplemental funding to accommodate an increase in expenditures due to COVID-19.

Allowability of Costs not normally charged to Awards:

This section is under review by Post Award Fiscal Compliance (PAFC), guidance will be posted on the PAFC website, as it becomes available.

Administrative Actions

The following award processes are managed by UW departments:

  • Prior Approval Requirement Waivers
  • Exemption of Certain Procurement Requirements
  • No-Cost Extensions on Expiring Awards

Proposal Submission

NSF is allowing flexibility on application deadlines on a case-by-case basis. Please reach out to the NSF Program Officer using OSP instructions for how to contact sponsors during these extraordinary circumstances. If flexibility is granted, include that information in your eGC1.

Department & Grant and Contract Accounting (GCA) Processes

NSF has extended reporting and Close Out requirements:

  • Extension of Financial and Other Reporting
  • Extension of Closeout

Internal to NSF

These two items are internal to NSF, no action needs to be taken by any UW unit:

  • Waiver of Notice of Funding Opportunities
  • Abbreviated Continuation Requests

Management, Accounting, & Analysis (MAA) and Internal Audit Only

These two items will be addressed by MAA and Internal Audit, no action needs to be taken by any other UW unit:

  • Extension of currently approved indirect costs
  • Extension of Single Audit Submission

Related Resources

Office of Research: Mitigating Impacts to Research due to COVID-19
Post Award Fiscal Compliance: Information for Sponsored Awards Impacted by COVID-19