(Updated) – A Summary of OMB M-20-17: Administrative Relief for Recipients of Federal Financial Assistance Impacted by COVID-19

by | Mar 20, 2020 | Federal Procedures

This post was updated on June 23, 2020 to include the extension of expiration dates for two areas of administrative relief as outlined in M-20-26 released on June 18, 2020.

On March 19, 2020, the Office of Management and Budget released M-20-17, Administrative Relief to Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations, notifying federal awarding agencies that they may provide administrative relief to an expanded scope of recipients of federal financial assistance (grants and cooperative agreements).

The expanded relief includes short term relief for administrative, financial management, and audit requirements under 2 CFR 200 (Uniform Guidance) “without compromising federal financial assistance accountability requirements.”

These flexibilities are in addition to those outlined in M-20-11 on March 9, 2020, Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19).

Agencies may also extend additional flexibilities on a case-by-case basis per their authorization to do so as outlined in 2 CFR 200.102 and are required to maintain records of the level of exceptions provided to recipients.

Below is a list of SOME of the administrative relief exceptions:

    1. Flexibility with SAM registration – Awarding agencies may relax the requirement for active SAM registration at the time of application. Current SAM registrants with active registrations expiring before May 16, 2020 can have a 60 day extension.
    • Flexibility with application deadlines – Agencies may extend application deadlines and place specific guidance on their websites and / or designate an agency program official for additional information. NIH has done this and their notice is here.
    • No-cost extensions on expiring awards – If the award is active as of March 31, 2020 and scheduled to expire prior to or by December 31, 2020, awarding agencies may automatically approve a no-cost extension for up to 12 months to the extent permitted by law.
    • Allowability of salaries and other project activities – Awarding agencies may allow recipients to continue to charge salaries and benefits to currently active federal awards from federal and non-federal sources and allow other costs necessary to continue approved project-related activities.  All costs must be consistent with applicable federal cost principles, benefit the project, and necessary records maintained. UPDATE: On June 18, 2020, OMB released M-20-26 that extended the expiration date of this flexibility to September 30, 2020. You can access OMB’s M-20-26 here.
    • Allowability of costs not normally chargeable to awards – Awarding agencies may allow recipients who incur costs related to the cancellation of events, travel or other activities necessary for the performance of the award to charge these costs to their award without regard to applicable sections of Uniform Guidance (2 CFR 200.403-405). Please read OMB M-20-17 for further details. Agencies must require recipients to maintain appropriate records.
    • Prior approval waivers – Awarding agencies are authorized to waive prior approval requirements as necessary to address the response but costs charged to federal awards must be consistent with federal cost policy guidelines and award terms.
    • Exemption of certain procurement requirements – Awarding agencies may waive procurement requirements centered on geographical preferences and preferences for small and minority businesses, women-owned business enterprises, and labor surplus area firms.
    • Extension of financial, performance and other reporting – Awarding agencies may delay report deadlines for up to three months and grantees may continue to drawdown funds without the timely submission of these reports.
    • Extension of currently approved indirect cost rates – Awarding agencies may allow grantees to use their currently approved negotiated indirect cost rate (predetermined, fixed or provisional) for one additional year without submitting a proposal. Proposal deadlines may also be extended if requested.
    1. Extension of closeout – Awarding agencies may allow the grantee to delay submission of pending financial, performance and other reports once the grantee provides proper notice. The delay may not exceed one year after the award expires.
    1. Extension of Single Audit submission – Awarding agencies that serve as cognizant or oversight agencies should allow recipients (and subrecipients) who have not yet filed their Single Audits with the Federal Audit Clearinghouse as of the date of memo M-20-17 (3/19/2020) with fiscal years ending through June 30, 2020 to delay completion and submission of their Single Audit reporting package six (6) months beyond the normal due date. Recipients and subrecipients do not need to seek approval of the extension but should have documentation of the reason for the delayed filing. UPDATE: On June 18, 2020, OMB released M-20-26 that extended the expiration date of this flexibility to December 31, 2020. You can access OMB’s M-20-26 here.

Read the full text of OMB’s M-20-17 for yourself. It can be found here. You can also read OMB’s extension of its administrative relief of the “Allowability of salaries and other project activities and “Single Audit submission” here.

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