COVID-19 Research Suspension Guidelines
All UTA research faculty should maintain a plan to suspend campus-based research and close their laboratory in the event that they or their lab personnel need to self-quarantine or suddenly halt laboratory research due to external circumstances or University guidance.
To assist with this planning, available below are the guidance and policies made available in March at the onset of UTA's campus shutdown in response to the coronavirus pandemic.
Research Activity Limitations
Principal Investigators (PIs) have the most knowledge to understand and determine the operational settings for their research within all safety precautions. Continuation of research within these guidelines are determined on a case-by-case basis and must prioritize the health and welfare of individuals over the conduct of research. Some research, for example, may have components that can be conducted remotely or in isolation. This may include individually conducted experiments in a lab. PIs will need to carefully consider activities that can continue in a safe environment versus those that need to be suspended in the interest of safety.
PIs have the discretion to pause all or part of operations in their labs or on their projects, if they feel that this is in the best interests of their laboratory/research team to avoid any health risks that may be posed by COVID-19. All research activity should be conducted remotely as much as possible.
Determining if Research Activities Can Continue
- All research activities on or off campus must at least meet the current standards for social distancing and other guidelines set forth by the CDC and other government agencies as well as any stricter guidance from their college, school, center, or facility or determined by a regulatory body (e.g. IRB/IACUC). For example, a facility may have access limitation requirements imposed that may limit the number of personnel in the facility. These limitations will need to be accommodated for research planning.
- Group or lab meetings, and even one-on-ones with personnel, should be held remotely. If a meeting must be in person, social distance practices are required and personal interactions should remain at six feet away.
- PIs should ensure personnel are comfortable with the environment and conditions under which they will perform research to the extent possible.
- PIs must review and consider all of the operational restrictions within this guidance to help determine which aspects of their research can or should continue. For example, a limitation to face-to-face interactions in human subject engagement may prevent the collection of necessary research data if there are not viable electronic alternative solutions.
- Any researcher (regardless of their position or rank) must not come to campus if they are sick. This includes essential personnel, which is why redundancy in all aspects of preparedness planning (and especially in communication plans) is vitally important.
Research Activity Planning
- Communications. If a communications plan for your research group is not already in place, designate points of contact so everyone receives timely information. All PIs should be prepared for a complete shutdown of activity on relatively short notice. Have a plan in place for your lab. How would you handle closures lasting hours, days, weeks? Think this through and take necessary steps to prepare.
- Plan for researcher time. PIs and research group leads should discuss approaches now, in the event that some personnel are unable to come to work. Such advanced planning will make future decisions straightforward and minimize disruption to research activities.
- Remote access. All students, post-docs, staff, and faculty involved in research projects should be prepared to ensure that they have access to information they need to carry out work remotely. This might include, for example, access to literature, access to existing datasets and research-related files, and access to meeting software (such as Teams). PIs should prepare to carry out meetings remotely should university, government, or community restrictions be put in place without much lead time. If you are unsure about whether you have access to such tools, it is wise to test them now. Examples of the types of research work that can be done remotely are: data analysis, literature reviews, writing proposals, reviews, or research papers, writing the background sections of theses, computational work, meetings, discussions, etc.
- Prioritization. Depending upon the nature of your research, you might consider prioritizing work that can only be carried out in your research facility, and put off work amenable to remote support, such as data analysis. Stockpiling results and data now that could be analyzed remotely in the future is a potential option that might create future flexibility in the event of future restrictions and limitations to facility access.
- Save samples along the way.If you are carrying out a long-term experiment and if it is feasible to freeze samples at specific steps, you might consider doing this more often.
Lab Safety Requirements
- Sanitize. All lab personnel using facilities should clean all contact surfaces when first entering a laboratory and before exiting the laboratory using the environmental cleaning and disinfection recommendations posted by CDC (link). Colleges, schools, centers, and facilities may provide additional guidance. University personnel from EH&S will be available to assist in securing cleaning solutions. Researchers are instructed post this flyer in their laboratories.
- Safety and Access Protocols. For individual laboratories, Core Facilities or other research space supervised by a Laboratory Director (LD), the supervising PI or LD has full authority to establish safety and access protocols for that facility, up to and including closing the lab or facility. The name and current contact information for the supervising PI or LD should be posted outside the door to such facilities, as well as a list of current access protocols.
- Prioritize. Consider suspending/postponing lower priority projects to allow for distancing and depopulation of the research space. Give priority to students needing to finish a degree, hard-to-interrupt experiments and to your most important research projects.
- Limit room occupancy. Establish modified or extended operational hours and “split shifts” among those hours, so that fewer people are in the lab at any given time.
- Individual Safety. Remember to maintain a safe environment while practicing social distancing. Working alone in a potentially hazardous lab space is never encouraged.
- Require PPEs as appropriate, but anticipate shortages of key PPE in the future, namely N95 masks and gowns, gloves and face shields. Begin limiting the number of personnel entering lab spaces that require donning of this PPE.
Ramping Down or Suspending Research
- Ramp Down of Lab. You may wish to use the Laboratory Ramp-Down Checklist (courtesy UC Irvine), adapted from peer institutions, to evaluate necessary steps in reducing research personnel density. Please note that this is not an all-encompassing list, or a list for which all items will apply to a specific type of research or research in a specific discipline. Rather, it is intended as a general tool to help inform researchers and focus their thoughts in preparing their plans and strategies.
- If you shutdown your lab, please be sure to inform EH&S and Amy Osborn (firstname.lastname@example.org) of the Office of the Vice President for Research.
- Suspending Research: For research conducted as part of a sponsored project, if a suspension of research activity is expected to result in:
- The disengagement of the PI of 3 months or more to the research;
- A Reduction of 25% or more in the time devoted to the project;
- A change in scope of work;
- A significant delay to complete the project on time; or
- A significant increase in costs to complete the project,
The PI should contact the postaward office (email@example.com) to help coordinate and communicate these impacts with program officers, managers, or sponsor personnel as required.
Conducting COVID-19 Research
If you are planning to receive SARS-CoV-2 virus containing samples for processing, such as nucleic acid extraction and subsequent amplification, or antibody testing, your laboratory must be BSL-2 certified by Environmental Health & Safety Office (EH&S). Performing procedures to concentrate or amplify/culture the virus in the samples is not allowed at UTA. These activities would require a BSL-3 laboratory.
To receive human specimens for health assessment or diagnose, prevent, or treat disease, laboratories must be Clinical Laboratory Improvement Amendment (CLIA)certified.
If you are planning to order materials to conduct testing of SARS-CoV-2 virus, coordinate with EH&S (firstname.lastname@example.org).
If you have a Human Pathogen Registration (HPR) on file with EH&S, use Human Pathogen Registration Update (HPRU) (Form CO-LS-F8) to indicate possible SARS-CoV-2 virus research.
If you are planning to start SARS-CoV-2 virus research, use Human Pathogen Registration (HPR) (Form CO-LS-F7) to start the BSL-2 commissioning of your research laboratory.
Research Personnel Work Activity and Assignments
All PIs and employee supervisors should assign work that can be performed remotely as much as possible. In some situations, this may require alternative work assignments from those normally assigned such as professional development or self-guided learning activities for new techniques or software familiarity. In either case, the activities must remain beneficial to the university or project with greater than typical latitude given. The intent is to lessen COVID-19’s sudden impact and the economic hardship felt by university employees. For research personnel whose work cannot be performed at home, PIs / supervisors should consider reassigned duties that can be performed remotely or help relieve work assignments from other employees. For research that is being delayed or suspended, this may also be a good opportunity for PIs to closely review their Data management Plans or practices, including data integrity in the collection, documentation, and other laboratory data practices of their research personnel. See the Open Science Framework for additional information. See also UTA’s COVID-19 Telecommuting FAQs.
Below are some professional development and training opportunities that are free or low cost for researchers, graduate students and postdocs whose normal activities have been disrupted.
Research Data Management and Sharing Resources/Training Opportunities
- Data Management Short Course for Scientists - ESIP (Earth Science Information Partners) in cooperation with NOAA and the Data Conservancy have compiled the resources for this course.
- Data Management Training Clearinghouse – a registry for online learning resources focusing on research data management.
- DataONE Education Modules - DataONE provides several lessons in PowerPoint format available for download that can be incorporated into teaching materials.
- Coursera: Research Data management and Sharing – [COURSE Started April 1] A five-week course designed to provide an introduction to research data management and sharing.
- NISO Research Data Management - the National Information Standards Organization has a primer to cover the basics of research data management.
- ICPSR Data Management & Curation - ICPSR is an international consortium of more than 750 academic institutions and research organizations and provides training in data access, curation, and methods of analysis for the social science research community.
- Educopia ETD+ Toolkit - Designed for training Graduate Students how to manage research for Thesis/Dissertations, but the curriculum can be used by anyone involved in research.
- MANTRA: Research Data Management Training - MANTRA is a free online course for those who manage digital data as part of their research project. Modules include data protection, rights, and access; sharing and licensing; and metadata and curation.
- Disciplinary RDM Training - This site lists Research Data Management materials specific to five areas (performing arts, archeology and social anthropology, health studies, psychology, and geosciences, social sciences & clinical psychology).
Proposal Preparation and Submission
Proposal deadlines. Grant and Contract Services (GCS) is prepared to submit proposals, even if personnel are working remotely. Our experience is that federal agencies are very flexible about deadlines under difficult circumstances beyond our control. However, if agencies are officially closed, proposals will most likely remain in a queue, pending resumption of agency operations – as has been the case during federal budget-related shutdowns. Please contact the GCS preaward team at email@example.com for any questions or concerns.
- AHA’s next proposal deadlines for research funding will be in August.
- Any changes to upcoming deadlines will be announced by July 1.
- CPRIT has made the difficult decision to suspend the first cycle of grant applications for fiscal year 2021 (FY 21.1) for Academic Research, Product Development Research and Prevention Program awards. In addition, CPRIT will not accept applications for CPRIT Dissemination of CPRIT-Funded Cancer Control Intervention awards for the rest of fiscal year 2020.
- CPRIT will withdraw all applications submitted in response to the Academic Research Program FY 21.1 Requests for Applications (RFAs) and the Prevention Dissemination RFA.
- CPRIT takes this action in response to the unexpected impact on the State’s budget caused by the COVID-19 pandemic and a projected decrease in oil and gas revenues. CPRIT will continue to 2 evaluate releasing RFAs for fiscal year 2021 and is committed to doing so if circumstances support it.
- Peer reviewers are currently evaluating applications submitted for the second review cycle of fiscal year 2020, with award recommendations set for approval at the August 19 Oversight Committee meeting.
- CPRIT expects the peer review and award recommendation timeline to remain on course for the Oversight Committee to approve awards in August.
- Late applications will be considered on a case-by case basis. Advanced permission to submit late applications is not required. Late applications must include a cover letter with enough detail about the delay to make a determination as to whether circumstances justify accepting the application late.
- Late applications will be considered on a case-by-case basis.
- If you are planning a RAPID proposal, NSF has suggested that you specifically address your ability to start work on the project given local restrictions (both institutional and otherwise) that may be in place that could potentially impact your ability to start or limit what you are proposing. Under the “stay home/shelter in place” declarations from Tarrant County and Dallas County, UTA is considered “Essential” and can continue to conduct business, including research. Although priority is given to conduct all research remotely if possible, onsite laboratory research can take place within certain limitations. All research must follow the research guidelines and requirements posted on our COVID 19 Research Impact webpage: https://resources.uta.edu/research/coronavirus/index.php. Important excerpts of this guidance are also available below.
- Because of RAPID proposal page limitations, we suggest a simple statement like the following although it will need to be adjusted based on your proposed research and any significant impacts on the ability to perform it.
- “Our university and COVID 19 related research are considered “essential” and the personnel and activities described in this proposal can be performed upon execution of an award. All research will be conducted within all safety precautions required by the CDC and other government agency requirements”.
- Because of RAPID proposal page limitations, we suggest a simple statement like the following although it will need to be adjusted based on your proposed research and any significant impacts on the ability to perform it.
- NSF 3/9/2020 Statement on COVID-19– describes NSF’s move to limit travel to and from NSF and utilization of virtual meetings for merit review panels and program manager meetings. NSF still expects to meet agency deadlines.
- NSF 3/4/2020 FAQs for Proposers and Awardees – describes considerations for various scenarios that involve travel or conference planning and the impact to awardees.
- SBIR/STTR solicitation deadline extended to March 23, 2020; up to April 3, 2020, in some cases. Additional extensions will be considered on a case-by-case basis.
- Due date extension requests will be considered on a case-by-case basis.
- Preapplications, letters of intent (LOIs) or full proposals can request an extension of up to 14 days. Continue to check specific funding opportunity announcements (FOAs) for most up-to-date information.
- DOE will determine if an extension to the application due dates are needed due to the COVID-19 crisis on a case by case basis. COs should work with their Program Offices to determine if an extension of due dates for applications is needed for any FOA currently published. If it is determined that an extension to the application due date is needed, COs must amend the FOA to extend the application due date in accordance with current policies and procedures.
- Program officials are advised to provide flexibility with upcoming deadlines to the extent allowable. Applicants are advised to contact program officials and grant managers to seek extensions for specific funding opportunities as applicable.
- No Deadline Extensions: There are currently no plans to modify existing application deadline dates.
- Application deadlines extended for Higher Education Challenge Grant Program, Beginning Farmer and Rancher Development Program, Agriculture and Food Research Initiative (AFRI), and AREERA. Other requests for permission to submit late should continue to follow existing policy by contacting the program contact in the Request for Application.
FDA, DHHS, OJP, NSA, and DARPA:
- Reference the funders website for updates regarding COVID-19.
- Due Date Extension: At this time, ONR and the other DOD agencies participating in this funding announcement have decided not to extend the submission date.
Tracking Costs Associated with COVID-19
Human Subject Research Expands to Phase 2 Under COVID-19 Limitations (Updated October 8, 2020)
UTA has expanded the scope of allowable activities for human subject research, referred to as "Phase 2." Phase 2 includes in-person activities involving close interaction or direct physical contact with participants, if the activities can be performed while wearing face coverings, eye protection, and gloves.
These types of activities can have varying levels of risk depending on the nature of the contact and the procedures being performed. Therefore, instead of setting additional limitations under Phase 2, these activities will be reviewed case-by-case to determine if they meet the criteria and can be conducted with appropriate safeguards in place to meet UTA requirements and protect subject safety.
A COVID-19 HSR Task Force will evaluate these activities. The Task Force consists of staff from Research Administration, IRB members, research faculty, and EH&S. To request authorization, investigators must describe their planned activities in the Request to Conduct Phase 2 HSR Request Form and attach it to their IRB protocol application submission (for new projects) or as a modification request (for an existing approved protocol).
Investigators conducting Phase 1 or Phase 2 human subject research must comply with the criteria and checklist requirements defined in this document: UTA HSR Ramp Up - Phase 1 & 2.
For questions, please contact firstname.lastname@example.org.
UTA’s Official Coronavirus Information Page: https://www.uta.edu/announcements/coronavirus
- Protecting Privacy & Confidentiality. Privacy and confidentiality of research subjects must be protected while implementing procedures involving phone, videoconferencing, or online data collection. Investigators should develop protocols and train study personnel on methods of protecting privacy and confidentiality during remote work. Advance preparation, such as removing identifiers from data (anonymize) or creating subsets of de-identified data and establishing secured, shared folders to permit remote access is also advised.
- Visit cancellations. If a study visit needs to be cancelled, participants should be informed of the reason and that they will be contacted again when the visit can be rescheduled. These messages to subjects do not require prior IRB approval.
- Immediate Hazards to Subjects. Federal regulations require prior approval for changes to research, unless the change is “necessary to eliminate apparent immediate hazards to the human subjects.” UTA IRB SOP IX.B. Eliminating immediate hazards may include actions to reduce potential exposure to COVID-19, or to continue to provide medically necessary study care (mental health assessments or continuance of study drug). If your situation meets the criteria for apparent and immediate hazard to subjects, you can implement a change immediately, without prior notice to or approval from the IRB. You will need to ensure that you are not introducing new/additional risks to subjects, and the change must be reported to the IRB within 5 business days (submit reports via email to email@example.com).
- IRB Operations: Federal regulations require prior approval for changes to research, unless the change is “necessary to eliminate apparent immediate hazards to the human subjects.” UTA IRB SOP IX.B. Eliminating immediate hazards may include actions to reduce potential exposure to COVID-19, or to continue to provide medically necessary study care (mental health assessments or continuance of study drug).
- Changes that do not represent apparent, immediate hazards should be submitted to the IRB per normal procedures, via a Modification request. IRB staff will prioritize review of modification applications for changes due to COVID-19. To facilitate review, please limit proposed changes to those necessary because of COVID-19, and email firstname.lastname@example.org to notify staff of an incoming COVID-19-related modification.
- IRB Committee Review. IRB review of pending, submitted applications will continue as usual. Studies that involve face-to-face interaction may be approved with the condition that enrollment cannot begin until after the restrictions are lifted.
- Studies Approved by Non-UTA IRB. Consult the Reviewing IRB for guidance on: 1) whether COVID-19 screening requires prior IRB approval, 2) whether/how to report the restrictions on face-to-face study procedures, 3) whether/how to modify an approved study to allow remote procedures.
Multi-Site Research. UTA investigators should communicate with external research team personnel in multi-site research regarding the potential impact the above restrictions may have on existing research. If protocol procedures are modified to address or eliminate face-to-face interactions or make other necessary changes, collaborators should be immediately notified and trained in the new procedures. If external sites have their own IRB oversight/approval of any portion of the project, the lead investigator should facilitate contact with the site’s IRB office to determine necessary actions. If external sites are fully relying on the UTA IRB, investigators at the sites should consult with their local IRB office to see if any actions are necessary.
Export Controlled Research
All researchers planning to work on a TCP or currently working on an active TCP must exercise caution and implement all of the requirements stated above with regard to research prioritization and lab access. Additionally, a new or amendment to TCP must be submitted and approved prior to the remote access of controlled information. The TCP or TCP amendment must incorporate all recommendations of the OIT Office. These include, but are not limited to, the following considerations:
- Research personnel working on a TCP must ensure that appropriate data security and confidentiality measures can be implemented for work to be conducted from off-campus locations. The loss of confidentiality, integrity, or inappropriate access could have severe adverse impact on the University, research area, or project.
- Emailing research data may not be appropriate or secure depending on the type of data and security requirements involved, and in some cases may be a violation of federal law. In particular, ITAR-controlled data must not be transmitted via normal email.
- Appropriate IT security and confidentiality measures must be consistent with the respective TCP, sponsor/contract requirements, and UTA Information Security policies https://www.uta.edu/security/policies/cloud_guidance.php. Research personnel must consider and double-check protocols, TCPs, grant or contractual obligations related to data security, storage, and confidentiality measures prior to allowing work from off-campus locations or taking physical/electronic data off campus.
If none of the above can be achieved, it is recommended revisiting the post award process to summarize the impact to a funded project (if this is funded and required for the scope of that funding).
Communication. ITAR controlled discussions are allowed to take place via Zoom because it is encrypted and secure, provided the PI ensures all participants are U.S. Persons and authorized personnel on an approved TCP. Any new methods of communication must be added to an approved TCP. Any digital transmission of ITAR controlled information outside the university must be limited to authorized TCP personnel only and comply with the end-to-end encryption standards in the federal regulations:
(ii) Secured using end-to-end encryption;
(iii) Secured using cryptographic modules (hardware or software) compliant with the Federal Information Processing Standards Publication 140-2 (FIPS 140-2) or its successors, supplemented by software implementation, cryptographic key management, and other procedures and controls that are in accordance with guidance provided in current U.S. National Institute for Standards and Technology (NIST) publications, or by other cryptographic means that provide security strength that is at least comparable to the minimum 128 bits of security strength achieved by the Advanced Encryption Standard (AES-128);
(iv) Not intentionally sent to a person in or stored in a country proscribed in § 126.1 or the Russian Federation; and
(v) Not sent from a country proscribed in § 126.1 of this subchapter or the Russian Federation.
End-to-end encryption is defined as:
(i) The provision of cryptographic protection of data, such that the data is not in an unencrypted form, between an originator (or the originator's in-country security boundary) and an intended recipient (or the recipient's in-country security boundary); and
(ii) The means of decryption are not provided to any third party.
(2) The originator and the intended recipient may be the same person. The intended recipient must be the originator, a U.S. person in the United States, or a person otherwise authorized to receive the technical data, such as by a license or other approval pursuant to this subchapter.
Award Management and Travel Restriction Impacts on Sponsored Projects
The Council on Government Relations (COGR) has developed FAQs Regarding COVID 19’s Impact on Federal Awards. These FAQs address the following concerns for award management and allowability of costs:
- Travel Charges, Including Cancellations
- Remote Work Environments
- Project Progress Obligations (addressing delays due to COVID 19)
- Salary Charges
- Allowability of COVID 19 Related Items on Grants
Grants and Contracts post award staff are available to assist and help address the issues noted above. Please contact post award for any questions or concerns you may have for award management at email@example.com.
- Inform AHA if your funded projects are placed on hold indefinitely. This could take the form of restrictions on human subject recruitment or visits with enrolled subjects, as well as inaccessibility to laboratories. AHA will support interim-year carryover requests due to suspension of research projects and allow rebudgeting.
- Unrefunded charges (conference registration, airline ticket, etc.) incurred with the intent to attend a scientific conference that was subsequently cancelled can be charged to an AHA grant.
- Reporting: Currently pending deadlines to submit scientific progress reports and patient recruitment/retention reports should proceed in a timely manner. The AHA is not extending these deadlines at this time.
- No Cost Extensions are always available. Please submit a Change Request in Grants@Heart. Awards currently on NCE may qualify for additional extensions.
- Salary Expenditures: AHA will allow payment of salaries on grants and fellowships for up to 60 days without pre-approval during periods of work.
- CPRIT will execute grant award contracts for applications already approved by the Oversight Committee. Please contact your program manager if you have any questions or need more assistance related to a specific grant project.
- The next FSR deadline (covering expenses incurred December 1, 2019 – February 29, 2020) is May 29, 2020. CPRIT rules permit an additional 30-day grace period (through June 28, 2020) to submit the FSR and supporting documentation. If a grantee is unable to file the FSR by the May 29 deadline, CPRIT’s rules include a process to defer submission of the FSR until August 29, the due date of the FSR for next fiscal quarter (covering expenses March 1 – May 31). The FSR filed by August 29 will include six months of project costs and supporting documentation, rather than three months.
- The grantee should submit a request to defer submitting the next FSR (due May 29) until August 29 through CGMS/CARS using the “Change Not Otherwise Specified” option under the “Change Request” tab. The grantee should submit the request by May 29. CPRIT will approve deferral requests related to delays caused by COVID-19.
- Grantees expending $750,000 or more in CPRIT grant funds or a combination of CPRIT and other state grant funds in the grantee’s fiscal year must complete a single audit, program specific audit, or agreed upon procedures audit no later than nine months after the end of the grantee’s fiscal year. If the grantee is unable to complete and submit a required audit by the due date because of the effects of COVID-19, please submit the notice that the audit will be late through “Change – Not Otherwise Specified” (CNOS) change request under the “Change Requests” tab in CPRIT’s Grant Management System. CPRIT requires only one CNOS request per grantee institution or entity.
- At this time, CPRIT will approve an extension of up to 90 days from the original audit due date for COVID-19 related delays. CPRIT may approve more time to file the audit if COVID-19 issues continue to affect the grantee’s ability to conduct the audit for an extended period.
- CPRIT’s rules require all grantees to submit required reports within 60 days of the anniversary of the grant contract’s effective date. These reports include annual progress reports, Historically Underutilized Business (HUB) forms, annual inventory reports, and revenue sharing forms. In addition, matching certification forms are due 30 days following the due date of the last quarterly FSR of the grant year. Some grantees must also submit quarterly progress reports.
- The grantee should contact the program manager if the grantee is unable to submit a required report by the reporting deadline. CPRIT will work with grantees to extend the deadline, if appropriate.
- The grantee may request an NCE via the “Change Request tab” of CGMS/CARS within the last six months of the grant. Once approved, CPRIT will amend the contract to reflect the new termination date. When requesting an NCE, the grantee should indicate that COVID-19 affected the grantee’s ability to complete the work on time.
- CPRIT recognizes that the potential effects of COVID-19 may affect the grantee’s ability to complete project goals and objectives within previously agreed timelines. CPRIT will work with the grantee to address goals and objectives changes necessary because of COVID-19. The grantee requests and CPRIT approves any changes to goals and objectives through CGMS/CARS.
- CPRIT recognizes that cancer research and prevention grantee staff may be unable to work on CPRIT-funded projects now due to or related to the COVID-19 disaster. Grantees should make every effort to perform work on the grant-funded project consistent with the grantee organization’s directives to employees regarding COVID-19, such as working remotely. However, in the event that personnel is unable to work or must reduce their work level, CPRIT will allow grantees to continue to charge salaries and benefits to currently active CPRIT awards if they are paid in a way that conforms to an established policy of the grantee and that policy treats both grant-supported and other activities consistently.
- Grantees must maintain records and documentation to support charges to the CPRIT grants for salaries and benefits for personnel not working or reducing their amount of work because of the COVID-19 disaster. CPRIT will provide additional instructions for grantees to track these costs.
- CPRIT will reimburse salaries and benefits up to the level reflected on the grantee’s Personnel Level of Effort (PLOE) form in place on February 29, 2020. This authorization applies to personnel costs incurred for the fiscal quarter March 1 – May 31, 2020. CPRIT will reassess the authorization for the fiscal period beginning June 1, 2020.
- CPRIT will reimburse otherwise allowable stipend payments to fellows and trainees who are unable to work due to or related to the COVID-19 disaster if the stipends are paid in a way that conforms to an established policy of the grantee and that policy treats both grant-supported and other activities consistently. Grantee institutions should provide documentation demonstrating the effect of the COVID-19 disaster. This authorization applies to stipend payments made in the fiscal quarter March 1 – May 31, 2020. CPRIT will reassess the authorization for the fiscal period beginning June 1, 2020.
- CPRIT will reimburse otherwise eligible costs associated with non-refundable grantee travel not taken because of the COVID-19 disaster. CPRIT will also reimburse otherwise allowable nonrefundable registration fees for conferences, seminars, or symposiums that the event host cancelled due to the COVID-19 disaster. Grantees must maintain records and documentation to support charges to the CPRIT grants for non-refundable travel and/or non-refundable registration costs resulting because of the COVID19 disaster.
- This authorization does not apply to travel booked or for event registrations made on or after March 20 (or the date that a grant organization implemented a no travel policy for its employees and students, if earlier than March 20.) The grantee should make every effort to minimize future non-refundable travel and event registration costs booked on or after March 20, and CPRIT reserves the right to reject a grantee’s reimbursement request if the grantee has failed to adequately protect against future non-refundable travel and event registration costs, even those related to the COVID-19 disaster.
- Closeout: Closeout reporting delays are allowed by notifying the assigned grants management specialist; this delay may not exceed one year.
- Additional project period extension beyond the first NCE requires prior approval per standard practice.
- Other Reporting Activities: Late Research Progress Performance Reports (RPPR), financial reports and invention reports will be accepted by notifying the assigned grants management specialist but will delay issuing grant awards until the reports are received and accepted.
- Clinical Trials: Project periods extensions beyond the seven-year timeframe are allowed.
- Salaries and Stipends: Salary and stipend charges will be allowable consistent with the organization's policies and payroll and effort verification processes. NIH may request documentation to confirm the requirements of the institutional policy.
- Travel: Nonrefundable costs for cancelled grant-related travel and conference registration fees are allowable if they would have otherwise been allowable. NIH-Supported Conferences
- Nonrefundable costs are allowable and may be requested as an administrative supplement by contacting the assigned grants management specialist.
- Clinical Trials: Institutions may request administrative supplements to cover unanticipated costs if unobligated balances are not available to rebudget; decisions will be made on a case-by-case basis.
- The NIH has announced Flexibilities Available to Applicants and Recipients of Federal Financial Assistance Affected by COVID-19.
- All NSF awards are automatically eligible for one year, grantee-approved no cost extensions; further extensions must be approved by NSF. Details regarding COVID-19 impacts to project schedule outside of one-time awardee extensions should be incorporated in annual progress report and discussed with the program officer, if applicable.
- Travel: Continue to follow all relevant sponsor and institutional policies and procedures and apply those practices consistently. NSF-Supported Conferences. Consider rescheduling the conference and/or repurpose the funds for a future award-related meeting.
- Continue to reference the Research Opportunities in Space and Earth Sciences — 2020 (ROSES — 2020) for questions related to allowability and allocability of costs related to COVID-19.
- Telework: Telework is encouraged where possible; telework should not keep researchers from meeting deadlines.
- Progress Report Due Dates: Progress reports for grants, cooperative agreements and interagency awards may be submitted as soon as practicable; delayed progress reports may cause delays in continuation funding.
- Continue to reference standard terms and conditions regarding prior approval requirements and defined of “changes in scope.”
- Cancellation of travel or change of meeting plans is not considered to be a “change in scope” requiring prior approval.
- Maintain appropriate records and cost documentation to substantiate costs related to project activities, as well as cancellation or other fees related to interruption of operations or services.
- No-cost extensions on expiring awards. (2 CFR § 200.308) Recipients must notify the CO if it is utilizing the regulatory authorities in 2 CFR 200.308(d)(2) to implement a no-cost extension to its award. The CO will then issue a modification to the award to change the expiration date. COs are authorized to provide no-cost extensions to current awards which were active as of March 31, 2020 and scheduled to expire on or before December 31, 2020. COs are also authorized to extend awards for which recipients have already utilized the one-time extension provided in 2 CFR 200.308(d)(2). A determination for non-competitive federal financial assistance as required by 2 CFR 910.126 will not be required for any no-cost extensions due to the COVID-19 crisis. COs are reminded to properly document the award when making the modifications to the expiration date.
- Abbreviated non-competitive continuation requests. (2 CFR § 200.308) Recipients with continuation applications due to be submitted between April 1, 2020 and December 31, 2020, will continue to follow the process as detailed in the ‘CONTINUATION APPLICATION AND FUNDING’ award term of their award. COs, in consultation with their Program Offices, will continue to process continuation awards according to the current policy; however they may determine that an additional statement from the recipient is required to verify that it is able to: 1) resume or restore their award/project activities; and 2) accept a planned continuation award. COs will need to inform recipients (on a case by case basis) when they determine that an additional statement is needed to execute the continuation award.
- Allowability of salaries and other project activities. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405) Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active DOE awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. The recipient is authorized to charge other costs to DOE awards that are necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. Recipients must not assume that supplemental funding will be available should the charging of such costs or other fees result in a shortage of funds to eventually carry out the project. If a funding shortfall is anticipated, recipients must contact the cognizant DOE CO to address the situation. DOE will evaluate the recipient’s ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances—based on subsequent project reports and other communications with the recipient. Recipients are required to maintain appropriate records and cost documentation as required by 2 CFR § 200.302 – Financial management and 2 CFR § 200.333 - Retention requirement of records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services. Also see Attachment 1 for additional guidance. 2
- Allowability of Costs not Normally Chargeable to Awards. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405, 2 CFR § 910.352) COs must determine the allowability of all costs charged by recipients under their awards. The provisions of 2 CFR 200 Subpart E and 2 CFR 910.352 apply for the allowability of costs. DOE may determine if recipient’s costs incurred related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to the COVID-19 crisis, are allowable. COs will make allowability determinations for these costs incurred on a case by case basis and must document the file accordingly. Recipients should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds. Recipients must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 - Financial management and 2 CFR § 200.333 - Retention requirement of records, to substantiate the charging of any cancellation or other fees related to interruption of operations or services.
- Prior approval requirement waivers. (2 CFR § 200.407) Recipients are required to obtain the prior approvals specified in 2 CFR § 200.308 (c) (i-viii). Recipients are reminded that they are to ensure that all costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award, except as specified in this guidance.
- Exemption of certain procurement requirements. (2 CFR § 200.319(b), 2 CFR § 200.321) DOE has waived the procurement requirements contained in 2 CFR § 200.319(b) regarding geographical preferences and 2 CFR § 200.321 regarding contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms. Recipients must document awards accordingly.
- Extension of financial, performance, and other reporting. (2 CFR § 200.327, 2 CFR § 200.328) Recipients must inform the DOE CO if they require an extension for the submission of any pending periodic financial, performance and other reports required by the terms of the award. DOE will extend the due dates for the submission of financial, performance and other reports for up to three (3) months. Recipient periodic financial, performance and other reporting requirements due between March 1 and August 1, 2020 can be extended up to 3 months from the date required in their awards. These reports must be submitted in accordance with the terms and conditions of their award.
- Contracting Officers at a minimum should consider— Taking into account mission critical project requirements (including Continuity of Operations and retention of critical recipient’s resources), particularly for cooperative agreements, after consulting with program officials, make any appropriate revisions to existing agreements. Assessing how the type of financial assistance award, its term, and relevant terms and conditions apply. Coordinating with the program and the recipient to determine if work can be done via telework by the recipient’s employees, and if the necessary resources are in place or can be implemented to accommodate telework, if appropriate. Discussing with the recipients their policies, collective bargaining unit agreements (if any), and other agreements with employees pertaining to paid leave, including weather and safety or equivalent leave related to COVID-19 for employees that cannot telework. In such situations, communications should include, if there is a need and a legal basis, a requirement that certain employees remain in a ready state status with pay. Communicating with recipients on any planned revisions to their paid leave policies, including weather and safety or equivalent leave related to COVID-19 for employees that cannot telework, and what the recipient’s process is for accomplishing such revision.
- The Department of Energy has provided guidance on Accommodating Interruptions Caused by COVID-19.
- The DOD will allow grantees to delay submission of financial, performance and other reports on currently active award accounts up to three months beyond the normal due date. For other deliverable due dates related to research awards, please contact DOD grants managers or program managers for guidance.
- The DoD is acting in accordance with OMB memo M-20-17, which encourages no cost extensions when possible. Current terms and conditions may already allow for a no-cost 1 year no-cost extension, with notification of to the grant office. For those that require prior approval, offices may waive the prior approval requirement for some grantees. If requested, each administrative office may grant a blanket no-cost extension on all awards to a given recipient. NOTE: In some cases, awarded funds may be cancelled prior to the revised period of performance.
- Salaries: DOD will allow recipients to continue to charge salary and benefits to currently active awards consistent with recipients' policy of paying salaries (under expected or extraordinary circumstances) from all funding sources, federal and nonfederal. To maximum extent practicable, recipients will be expected to invoke or institute any and all reasonable mitigation practices and actions to lessen the cost to the government during this crisis.
- Travel: DOD will allow nonrefundable travel expenses incurred for travel cancelled due to COVID-19 to be charged to active awards (aligned with OMB guidance and in concurrence with institutional policy).
- Telework: Telework is encouraged where possible; telework should not keep researchers from meeting deadlines.
- No Cost Extensions: Continue to reference standard NCE requirements and procedures. Grants officials have been advised to be flexible in considering requests.
- Rebudgeting: Continue to reference standard rebudgeting requirements and procedures (and waived prior approvals). Grants officials have been advised to be flexible in considering requests.
- Salaries: Salaries and benefits for work performed to meet the project activities (including telework) are allowable, regardless of the location where those duties are performed. Charges to the award should only be made when the work is performed within the policies for allowable remote/telework and/or emergency operations; salary and stipends for research personnel cannot be charged to research awards unless research is being performed or as approved on a case-by-case basis. Allowable work activities include data analysis, preparation of articles and papers based on the research, monitoring subrecipients, care of research animals, direct charged administrative costs, etc.
- Travel: Alert your program officer about cancelled or interrupted conference/meeting travel plans; consider alternate arrangements (e.g., holding meetings virtually)
- OMB guidance on Travel: If a traveler has charged (e.g., through prepayment or a travel advance) an airline ticket or other travel cost to a sponsored project and that trip is later cancelled, the credit must accrue to the sponsored project (see 2 CFR 200.406). Some airlines are offering full refunds for trips that need to be cancelled due to COVID-19; in these instances, the refund should accrue to the grant, either directly through the institution’s travel system or via reimbursement from the traveler. If a traveler cancels a trip and accrues a credit on their personal account, the traveler should follow institutional policy for how to track and manage the credit.
- If a traveler can return home from travel (domestic or foreign) but at much greater cost than usual, is the additional cost allowable on the grant? The traveler should follow their employer’s institution’s policy for emergency situations. If there is no specific policy, the traveler should follow the common practice of the institution. The institution’s policy or practice related to the criteria for evaluating the status and extent of the emergency and the level of relief that is considered appropriate to those circumstances should be followed.
- Financial Reporting: ONR grants do not require interim financial reporting through the submission of a SF-425, but rather ONR uses the payment request process for that information. Thus, this paragraph with respect to financial reporting does not affect ONR grants.
- Performance Reporting: ONR grant annual interim Research Performance Progress Reports (RPPR) are due on June 15, 2020. For any awards that are active as of that date, and that require an interim performance report on that date, recipients still should submit this report on June 15. Reports submitted after this date will be accepted and not deemed late. Please note that the submission portal for Principle Investigators funded by ONR grants is closed after August 15, 2020. We will update this FAQ if access to the submission portal is extended.
- Federally-Owned Property Reporting: If your ONR award has federally-owned property (this does not include exempt property) accountable to it and the award’s annual property reporting period falls into the effective timeframe covered by OMB Memorandum M-20-17 and Attachment 1, the annual property report due date, specified in REP Article III, Section C.1 is delayed up to 3 months.
- Patent Reporting: If any patent-related information or reports required by REP Article III, Section D.1 are due during the effective period covered by OMB Memorandum M-20-17 and Attachment 1, the patent information/report due date is delayed for up to 3 months.
- Subawards and Executive Compensation Reporting: If any information or reports required by appendix A to 2 C.F.R. Part 170 (as specified in REP Article IV) are due during the effective period covered by OMB Memorandum M-20-17 and Attachment 1, then that information/report is delayed for up to 3 months.
- Salary: Continue to charge salaries and benefits to currently active Federal awards consistent with each recipient’s policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal
- Extending Awards: Extend awards that were active as of March 31, 2020 and scheduled to expire prior or up to December 31, 2020, at no-cost for a period of up to 12 months. ONR will modify all existing ONR grants ending between March 31, 2020 and December 31, 2020, to provide a one-year, no-cost extension with the following caveat as noted in the DoD-wide supplemental T&C:
- Project-specific final financial and performance reports will be due 120 days following the end date of the extension.
- If all funds were provided at the start of a project, please be aware that funding expiration statutes may prohibit extensions. Please contact the cognizant ONR Regional Office for specific guidance if ONR fully funded your grant at award.
- IDC Rates: Use the currently approved indirect cost rates (i.e., predetermined, fixed, or provisional rates) to recover indirect costs on Federal awards.
- Recipients must have an expired indirect cost rate extended by their cognizant agency for indirect cost prior to using it for recovery of indirect costs. Recipients must contact their cognizant agency for indirect cost in order to request the rate extension of existing rate agreements and that request must be approved by the cognizant agency for indirect cost.
- Closeout Submissions: Delay submission of any pending financial, performance, and other reports required by the terms of the award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the grantee to the agency.