On March 10th, the Office of Management and Budget (OMB) released Memorandum M-20-11 to the Heads of Executive Departments and Agencies, identifying several  agency actions to relieve short term administrative, financial management and audit requirements under 2 CFR 200, Uniform Administrative Requirements, Cost principles and Audit Requirements for Federal Awards, without compromising Federal financial assistance accountability requirements.  

OMB is permitting federal agencies to grant exceptions to current regulations in instances where the agency has determined that the purpose of the Federal awards is to support the continued research and services necessary to carry out the emergency response related to COVID-19.  These exceptions are time limited and are only applicable for those awards that support the continued research and services necessary to carry out the emergency response related to COVID-19 during the period formally declared by the Department of Health and Human Services through the 90 Day Public Health Emergency Declaration (Public Health Emergency Period).

The awarding agencies are authorized to take the following actions, listed in summary below.  Please review the Memo for full details.

• Flexibility with SAM registration/recertification
• Waiver for Notice of Funding Opportunities Publication
• Pre-award costs
• No-cost extensions on expiring awards
• Abbreviated non-competitive continuation requests
• Expenditure of award funds for salaries and other project activities
• Waivers from prior approval requirements
• Exemption of certain procurement requirements
• Extension of financial or other reporting
• Extension of single audit submission

We expect to receive further guidance from our federal sponsors as they implement these exceptions.  ORPA will communicate these changes as they occur.