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GA Frequently Asked Questions: Post Award

Frequently Asked Questions (FAQs)

Post-Award Management, Allowable Costs, Reporting

What documentation should we be keeping in regard to the impact of COVID-19 and how should we be tracking expenses related to COVID-19?

Grants & Contracts Administration (GCA) is keeping a record of institutional communications that memorialize decisions or guidance to campus regarding research activity. PIs are similarly advised to document their key decisions and actions taken in response to GCA guidance, and to track as best they can the costs their grants incurred to implement UMass Chan’s guidance.

Will my grant have to pay for project-related costs incurred during the university’s ramp down in research operations if we aren’t able to work on the project (e.g., animal per diem, idle lab staff, etc.?)

In general, the answer is “Yes,” your grant will likely be required to cover the costs incurred during the ramp down in research operations -- provided UMass Chan would likewise require a non-sponsored fund to pay for the same cost in similar circumstances. Put the other way around, if the university would not allow a certain cost to be incurred on a non-sponsored fund during the ramp down, the university will not allow the same cost to be charged to a sponsored project. This practice adheres to the federal government’s Uniform Guidance (2 CFR §200.403) requirement that costs be incurred “consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.”

Is there a way to obtain additional funding to recoup the costs my lab incurred during the pause on my NIH-funded human subjects research?

NIH issued a notice on March 16, 2020 stating that if unanticipated costs related to clinical trials or human subject research are identified due to impacts of COVID-19, and unobligated balances are not available to rebudget, recipients may request administrative supplements from NIH. Please contact OSP regarding submission of an administrative supplement to PA-18-591.

My grant is ending. Should I wait until we are back on campus before reallocating my effort and the effort of my laboratory staff?

No. If grants are ending, PAs and DEFAs must be done. Unless a no-cost extension has been approved by the sponsor, payroll charges on grants must stop as of the end of the project period.

If the grant is ending, the effort must be moved to discretionary funds. If the department/PI is requesting that the effort be reallocated to another grant, they will need to provide justification/assurance that the effort/work is ongoing in the current state of limited on-campus work.

I am a principal investigator and am required to work from home as a result of COVID-19. Can I charge supplies relating to telework (i.e., such as a laptop, printer, office supplies, etc.) to my grant?

No. These types of expenses are considered indirect (Facilities & Administrative) costs, and generally are not appropriate as a direct cost unless specifically approved by the sponsor. The ramp down in research operations at UMass Chan does not change this fact. If you need to work remotely from home, please consult with your department to identify whether computing resources are available.

I have a temporary employee/student worker who is no longer able to work on my grant as a consequence of the COVID-19 situation. What are my options for keeping this individual on the university payroll?

If a temporary employee is no longer able, for whatever reason, to work on a sponsored project, the principal investigator (PI) should first determine if the individual can legitimately be reassigned to other grant-funded activities. If yes, the individual’s appointment should be moved to the appropriate award. If there is no activity the individual can perform then they will no longer be paid.

What percent effort should I or my exempt laboratory staff charge to my grant during a pause in research activity?

Employee’s effort should be charged at the rate in effect at the time that the pause in research activity was announced or, if applicable, at a rate that can be documented to have been planned at least 30 days prior to the announcement of a pause in research activity.

What if an NIH-funded project requires an immediate change that affects the outcomes or trajectory of a clinical trial or human subjects research protocol? Do the changes need to be approved by the program officer?

If you need to make changes because of safety, that’s top priority. The first administrative authority would be IRB. Do what you need to do. Then please get in contact with your program officer. Please don’t let administrative concerns with the agency get in the way of public health or patient safety.

How might we have to proceed with grants and contracts from industry, foundations and other nonfederal entities in regard to changes in costs or expected outcomes?

Due to the heterogeneity of nonfederal sponsors, it is not easy to make a blanket statement. We advise following the general principles from federal grants (e.g., if a cost wasn't allowable on the grant in regular times, it likely won't be allowable now), but more specific issues around effects of timelines on nonfederal projects will likely have to be discussed with the sponsor. If the terms of the award need to be amended, OSP personnel are available to help through this process and discussions.

My study may be impacted by the pause, which could lead to delays in completing my study by the end of the project period. What should I do?

Most federal sponsors allow for a one-time no cost extension for 12 months at the end of the project. Sponsors are considering the impact of COVID-19 on project timelines.

I am working on COVID-19 research project in my laboratory. Is it acceptable to charge personnel and supply costs to the Chartstring created for tracking?

Yes. If any faculty or staff are working on a COVID-19 research project, you should allocate the appropriate level of effort and project costs to the Chartstring being used for tracking.

If you are approved to work on a COVID-19 research project please contact Grant Accounting to obtain a Chartstring for research being conducted prior to receiving sponsored funding for the project.

Should I continue to approve our subrecipient invoices if they have lab restrictions due to the COVID-19 pandemic?

Yes. Any flexibilities related to the COVID-19 pandemic from our sponsors are flowed down to the subrecipients. Invoices from subrecipients represent costs incurred according to their institutional policies. Therefore, these are allowable costs on the award.

Can travel cancellation expenses and fees caused by the COVID-19 pandemic be charged to sponsored awards?

Yes. Under the OMB notices for Managing Flexibility due to COVID-19, agencies have relaxed restrictions for charging cancellation expenses and fees to awards provided the practice is in alignment with University guidance and reasonableness.

Some sponsored agencies have not specifically addressed cancellation expenses. At the current time, we recommend that all reasonable fees be charged to awards and documented. If agencies issue alternative guidance, these expenses will need to be removed.

Departments must retain documentation relating to the cancellation costs charged to a grant in accordance with record retention requirements.

I need to purchase airfare for future travel. Can I purchase refundable airfare and charge it to a grant? What should I consider when booking future sponsored travel?

Yes. Refundable airfare purchased during the COVID-19 pandemic may be charged to a grant.

In an effort to minimize cancellation costs, we recommend you:

Register your travel in the Travel Registry at https://travelregistry.umasscs.net/.
Book travel through the University’s preferred vendors.
Purchase refundable airfare.
Consider lodging that doesn’t require a lodging deposit.
When planning or attending conferences consider all costs that may be associated with the cancellation.
Remain updated on the COVID-19 by visiting UMass Chan Medical School’s Coronavirus Updates website for updated information.

I had planned to travel to a conference to present my federally funded results, but the conference was cancelled due to precautions regarding COVID-19. May I still charge the travel-related costs to the grant? Can I charge trip cancellation insurance to my federal grant? Can I return early from a trip if I’m worried about being exposed to COVID-19 grant?

See NIH GPS 7.9.1 for federal guidance relating to charges to awards for travel, conferences and related expenses due to the coronavirus. Please continue to follow the University Policies and any cost principles described in your award or the sponsor’s policies and procedures. (Note, however, that trip cancellation insurance is typically unallowable on grants unless the sponsor expressly states otherwise.) Please recall that all costs to a Federal award, including costs for travel, must meet the requirements of the Uniform Guidance (2 CFR 200). In general, in order for a travel cost to be allowable, it must (a) benefit the project, (b) be necessary and reasonable for the performance of the project; and (c) not exceed what a “prudent person” would pay under the circumstances at the time the decision was made to incur the cost. The Federal government also considers whether (a) the cost was necessary for the proper and efficient performance of the project, and (b) the cost was prudently incurred in light of UMass Chan’s responsibilities to its employees and students.

Will Grant Accounting continue to submit invoices and financial reports?

Yes. Grant Accounting continues to operate remotely and make every effort to meet sponsor deadlines.