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The Office of Management and Budget (OMB) has relaxed key requirements of 2 CFR 200 on grantees, including extending Uniform Audit submissions up to six months, extending indirect cost rates, and expanding definitions of reimbursable costs, among other financial and administrative requirements. The guidance recognizes the need for flexibility for recipients affected by the loss of operational capacity and increased costs due to the novel coronavirus (COVID-19) crisis.

OMB issued Memorandum M-20-17 on March 19, 2020, providing short-term relief for grantees from certain administrative, financial management, and audit requirements applicable to these federal assistance awardees under 2 CFR 200, “Uniform Administrative Requirements.” Relief is granted for the following, subject to relevant agency adoption:

  1. Flexibility with System for Award Management (SAM) Registration: Agencies can relax requirements for active SAM registration at time of award application to expedite funding. However, grantees must register in SAM by award date.
  1. Flexible Grant Application Deadlines: Agencies can accept unsolicited and competing applications at their discretion.
  1. Waiver of Notice of Funding Opportunities (NOFO) Publication: Agencies can publish emergency NOFOs with less than thirty-day notice.
  1. No-Cost Extensions on Expiring Awards: Agencies may extend active awards for up to twelve months. Project-specific reports will be due ninety days after end of extension date.
  1. Allowability of Salaries and Project Activities: Agencies may allow recipients to continue to charge salaries and benefits to current active awards (under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal, during interruption of operations or services. Records and cost documentation must be maintained, identifying interruption of operations or services. A policy should also be developed in this regard.
  1. Allowability of Costs Not Normally Chargeable to Awards: Agencies may allow recipients who incur costs related to event cancellation, travel, and pausing and restarting grant activities to charge them to the award. However, recipients should not assume additional funds will be available if a shortage of funds to eventually carry out the activity resumes. Again, any such charges must be substantiated.
  1. Waiver of Prior Approval Requirements: As necessary, agencies may waive prior approval requirements.
  1. Exemption of Procurement Preference Requirements: As necessary, agencies may relax or eliminate requirements for geographical, small business, women business enterprise (WBE), and other labor preferences.
  1. Extension of Financial Performance and Other Award Reporting Requirements: Awarding agencies may allow grantees to delay submission of financial, performance, and other reports up to three months beyond the normal due date. Grantees may continue to draw down federal funds without the timely submission of these reports.
  1. Extension of Currently Approved Indirect Cost Rates: Awarding agencies may allow grantees to continue to use the currently approved indirect cost rates (i.e., predetermined, fixed, or provisional rates) to recover indirect costs. Grantees may request extensions to use the current rates for an additional year without submission of an indirect cost proposal. Agencies may also grant requests for extensions of indirect cost rate proposal submission to finalize current and establish future rates.
  1. Extension of Closeout: Agencies may allow grantees to delay closeout if provided proper notice of the reporting delay. This delay may not exceed one year after the award expires.
  1. Extension of Single Audit Submission: Awarding agencies can allow recipients with fiscal year-ends through June 20, 2020, to delay the completion and submission of Single Audit reports to six months beyond the normal due date. No approval is necessary to take advantage of this extension. 
  1. Abbreviated Non-Competitive Continuation Requests: Awardees may request award continuation for awards expiring from April 1 to December 31, 2020.

Questions should be directed to the OMB’s Office of Federal Financial Management, Grants Management at GrantsTeam@omb.eop.gov.

The OMB Memorandum can be found at https://www.whitehouse.gov/wp-content/uploads/2020/03/M-20-17.pdf. Look to each agency for additional specific guidance in this regard.

If you have questions, please contact BRG’s Government Contracts and Grants practice leaders, Mary Karen Wills (mkwills@thinkbrg.com) or Ryan Byrd (rbyrd@thinkbrg.com).