Responding to COVID-19

The Office of Management and Budget (OMB) issues policies that apply across the Government as memoranda, usually addressed to the heads of U.S. Federal executive departments and agencies. OMB policies related to COVID-19 can be found here https://www.whitehouse.gov/omb/information-for-agencies/memoranda/. In particular, OMB memoranda M-20-27 modified the policies announced in M-20-11, M-20-17, and M-20-20.

DOE issues policies to its contracting officers who sign financial assistance (grants and cooperative agreements) as Financial Assistance Letters. The DOE policies are published at https://www.energy.gov/management/financial-assistance-letters.

If you are a Principal Investigator (PI), DOE recommends first discussing concerns with your institutional Office of Sponsored Research (or equivalent). PIs are also always welcome to discuss matters with DOE Program Managers.

Requests for official clarification of policy or prior DOE approval must be requested from an institutional official to the DOE Award Administrator and Agreements Officer identified in the Assistance Agreement for your award. DOE Program Managers cannot commit the Government to a particular position.

The Substantial Involvement clause in cooperative agreements is unique to each cooperative agreement. Questions about how to interpret that clause should be directed to the DOE Award Administrator and the DOE Agreements Office identified in the Assistance Agreement.

Yes, 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 and/or any cancellation or other fees related to interruption of operations or services.

Recipients of DOE awards are subject to the audit provisions of 2 CFR 200 and 2 CFR 910. Proper record-keeping and following institutional policies and procedures are required by regulation.

The answer to that question depends on (a) whether those personnel are working on the award and (b) the nature of the recipient institution’s policies governing payroll continuity in unexpected or extraordinary circumstances, such as the current COVID-19 pandemic.

• For personnel currently working on an award, whether on-site or remotely, recipients are authorized to continue charging salaries, stipends, and benefits to active SC awards consistent with the recipient’s policies governing telework and emergency personnel operations during unexpected or extraordinary circumstances.
• For personnel who are not currently working on that award, and are thereby outside the recipient’s policies governing telework and emergency or essential personnel, the answer (and its associated requirements) hinge on the recipient institution’s written policies and procedures governing operations during unexpected or extraordinary circumstances.
  • If institutional policies authorize the ongoing payment of salaries, stipends, and benefits from all sources (Federal and non-Federal) regardless of whether or not work is being performed during unexpected or extraordinary circumstances, the recipient institution must follow those policies to ensure that it is treating all costs consistently, regardless of the source of those funds. In this circumstance, the recipient institution is not relying on the deviation authorized by OMB but is instead following the standard requirements for cost allowability.
  • If institutional policies do not allow the ongoing payment of salaries, stipends, and benefits during unexpected or extraordinary circumstances, the recipient institution is relying on the deviation authorized by OMB and must follow all policies and procedures required by the OMB deviation prior to charging such costs to Federal awards.

    The OMB deviation only applies to personnel whose salaries, benefits, or stipends would not be paid by the recipient institution in the event of natural disasters, including pandemics.

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.

A recipient institution’s costs incurred related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award due to the COVID-19 crisis are allowable if consistent with the recipient institution’s written policies.

• Nearly all awards from SC authorize rebudgeting of funds if the change does not constitute a change in scope. PIs should work with their institutional Office of Sponsored Research (or equivalent) to determine if the recipient institution must seek agency prior approval.
• If cancellation fees are prohibited by the recipient’s written policies, such costs may be chargeable to a Federal award if they were incurred before June 16, 2020, when some previously-authorized flexibilities issued by OMB expired.
• If vouchers have been granted for any of the travel expenses affected by COVID-19, recipient institutions are required to use the vouchers and may not request additional support.

Direct charges for laptops, desktops and other equipment are allowable only when required for the work supported by an award. Laptop and desktop computers may be procured with grant funds consistent with recipients’ institutional policies and treatments of cost.

Yes. When awards are issued or modified, funds are transferred into DOE’s payment systems (ASAP for awards under advance payment, VIPERS for awards under invoice payment). Both payment systems are continuing normal operations, including direct deposit payments to recipient institutions.

If the budgetary change does not change the scope on an award, no agency prior approval is required unless the terms of an award specify otherwise. Recipient institutions must not assume that additional funds will be made available to recoup the costs of repairing or replacing equipment. A discussion with your DOE Program Manager is advisable before your Office of Sponsored Research (or equivalent) requests prior approval from the DOE Award Administrator and Agreements Officer identified in the Assistance Agreement for rebudgeting funds on an award.

For research awards, changes in the budget that do not create a change in scope do not require agency prior approval. (See 2 CFR 200.308(d)(4)) PIs should work with their institutional Office of Sponsored Research (or equivalent) to ensure that the student’s retention is consistent with any institutional policies and procedures and to determine if the recipient institution must seek agency prior approval.

Requests for a potential change in scope must be sent by the recipient institution’s Office of Sponsored Research (or equivalent) to the Award Administrator, Agreements Officer, and Program Manager identified in the award documents. The DOE Program Manager will assess whether or not the proposed change is considered a change in the scope of the award. From this assessment, the Agreements Officer will respond with one of three possible determinations: (a) the proposed change is not a change in the scope of the award, and thus does not require agency prior approval, (b) the proposed change is a change in the scope of the award and is approved, or (c) the proposed change is a change in the scope of the award and is not approved.

SC has not issued any targeted Funding Opportunities dedicated to COVID-19 related research.

SC has prioritized access to its user facilities (https://science.osti.gov/User-Facilities) for COVID-19-related research. SC created the National Virtual Biotechnology Laboratory (NVBL) to coordinate the abilities of the DOE National Laboratory system, including its relevant user facilities. Information can be found at https://science.osti.gov/nvbl.

All SC FOAs are published at https://www.Grants.gov, and Program Announcements to the DOE National Laboratories are published at https://pamspublic.science.energy.gov.

Yes. SC is continuing to make recommendations for award in all of its program areas. Peer reviews of applications and proposals continue, with peer review panels meeting virtually rather than in-person.

No. Reviewers are charged with assessing the quality of a proposal or an application. Reviewer comments about past performance must be grounded in reasonableness: DOE will read these comments in light of the situations affecting applicants and investigators. Applicants and investigators are encouraged to explain any impact of the COVID-19 pandemic on their research.

SC continues to recommend research proposals to be awarded, knowing that research projects require time to ramp-up and that the evolving situation may continue to pose challenges.

Applicants requesting support for hosting or organizing conferences, workshops, or scientific meetings should provide contingency plans in their applications in the event that the meeting needs to be changed to a virtual mode. Applicants must confirm whether their planned event will still take place before an award is made.

SC extended a number of application deadlines in March and April, 2020, during the initial wave of disruptions. Future application deadlines will be established with an awareness of the then current status of operations at applicant institutions.

Yes. No-cost extension requests may be submitted in the Portfolio Analysis and Management System (PAMS) at https://pamspublic.science.energy.gov by the sponsored research officer, business official, or authorized official (SRO/BO/AO) associated with the award. If an award is not listed, please contact your DOE Program Manager.

SC has a long history of liberally authorizing no-cost extensions, but extensions may not be authorized solely for the purpose of using unspent funds.

SC always encourages prompt and timely submissions.

Yes. At some point, conferences and workshops will resume, face-to-face collaboration will become feasible, and travel to experimental sites will return. While applications may not know precisely when those costs will be incurred, it is reasonable to request sufficient funds to cover reasonably necessary travel.

A recipient institution’s costs incurred related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award due to the COVID-19 crisis are allowable if consistent with its written policies.

• Nearly all awards from SC authorize rebudgeting of funds if the change does not constitute a change in scope. PIs should work with their institutional Office of Sponsored Research (or equivalent) to determine if the recipient institution must seek agency prior approval.
• If cancellation fees are prohibited by the recipient’s written policies, such costs may be chargeable to a Federal award if they were incurred before June 16, 2020, when some previously-authorized flexibilities issued by OMB expired.
• If vouchers have been granted for any of the travel expenses affected by COVID-19, recipient institutions are required to use the vouchers and may not request additional support.

SC understands that travel restrictions may continue to occur through the remainder of the public health emergency and will likely affect the progress of SC-funded research. Recipient institutions must contact their Award Administrator, Agreements Officer, and Program Manager to alert them of the delays. SC is committed to working with its applicants and recipients during this public health emergency.

Progress reports are submitted through the Portfolio Analysis and Management System (PAMS) at https://pamspublic.science.energy.gov. We expect that results and progress may be impacted by events beyond the control of any recipient or investigator.

Yes, progress report submission remains available in the Portfolio Analysis and Management System (PAMS) website (https://pamspublic.science.energy.gov) even after a report’s due date. Please keep in mind that delays in submitting a progress report will usually cause a commensurate delay in awarding a continuation with the next budget period’s funds.

Yes, although progress reports only become available for submission in the Portfolio Analysis and Management System (https://pamspublic.science.energy.gov) one month before they are due.

The SBIR/STTR Program Office plans to modify the timing requirements for allowing current Phase I awardees to apply for Phase II support. Please contact the SBIR/STTR Program Office at [email protected]. Details will be contained in future Phase II Funding Opportunity Announcements.

Yes. The business official or authorized official (BO/AO) associated with the award may submit extension requests in the Portfolio Analysis and Management System (PAMS) at https://pamspublic.science.energy.gov. Note that requesting an extension may alter when a Phase I awardee may submit a Phase II application.

Yes. The business official or authorized official (BO/AO) associated with the award may submit extension requests in the Portfolio Analysis and Management System (PAMS) at https://pamspublic.science.energy.gov. Note that requesting an extension may change when a small business is eligible to apply for subsequent Phase II funding.