Coronavirus Disease 2019 (COVID-19) Updates Related to Sponsored Programs

Page Updated: Friday, July 3, 2020 9:29:42 AM CDT

Check here for updates regarding how COVID-19 is affecting sponsored programs at UW-Madison. If you have any information to share, please e-mail us at rspinfo@rsp.wisc.edu. Read updates to UW-Madison Campus Operations: https://covid19.wisc.edu/

COVID-19 Impact Reporting

OVCRGE Research Recommendations

Title Description
OVCRGE Research Reboot – Return to Research Phase 2 More information about returning to the campus research space (July 1, 2020)
OVCRGE Research Reboot – Return to Research Phase 1 Information about returning to the campus research space (May 27, 2020)
OVCRGE Memo on Travel Restrictions UW-Madison research travel guidance in response to COVID-19
OVCRGE Message on Research Guidance Notes on conducting research at UW-Madison amidst telecommuting and COVID-19 concerns.
OVCRGE Research Recommendations Answers to your questions and information about accessing resources, support for researchers, remote work, and more.
OVCRGE Research Update Research enterprise update from the Vice Chancellor for Research and Graduate Education (March 31, 2020)

UW Resources

Title Description
COGR Repository for IHE Guidance A collection of resources from various institutions of higher education.
OVCRGE Message on Human Subjects Research Message for those conducting human subjects research.
UHS COVID-19 Updates Up to date information from the University of Wisconsin - Madison's University Health Services including campus-wide FAQs.
UW Health Sciences IRB Updates UW-Madison’s Health Sciences IRB has created this webpage to share updates and provide answers to COVID-19 related questions related to Human Subjects.

Sponsor/Organization Updates

Organization Description
American Heart Association
Bader Philanthropies, Inc.
Brain & Behavior Research Foundation (BBRF)
  • BBRF Deadline Extension - The Brain & Behavior Research Foundation is extending the deadline for the 2020 BBRF Young Investigator Grant to March 31, 2020.
Cayuse
Department of Commerce
Department of Defense
Department of Education
Department of Energy and DOE National Labs
Department of Health and Human Services
(see NIH for separate listing)
Department of Interior
Department of Justice
Environmental Protection Agency (EPA)
Foundation for Food and Agriculture Research (FFAR)
Gordon and Betty Moore Foundation
Institute of Museum and Library Services
  • See IMLS updates regarding important deadlines and award management (March 23)
John Templeton Foundation
Leidos (DOD and DHHS flow-through sponsor)
Mellon Foundation
National Aeronautics and Space Administration (NASA)
National Endowment for the Arts (NEA)
  • NEA FAQs - National Endowment for the Arts FAQs for Applicants & Awardees in Response to COVID-19
National Endowment of the Humanities (NEH)
National Institutes of Health (NIH)
National Science Foundation (NSF)
  • NSF Implementation of OMB Memorandum M-20-17, entitled, “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations” dated March 19, 2020
  • NSF COVID-19 Information - The National Science Foundation provides guidance on COVID-19 and RAPID Research opportunities.
  • Impact On Existing Deadline Dates - National Science Foundation (NSF) Notice, March 18, 2020. Proposers are advised that NSF will be extending the deadline date for the solicitations or Dear Colleague Letters.
  • NSF COVID-19 FAQs - Frequently Asked Questions (FAQs) about the Coronavirus Disease 2019 (COVID-19) for National Science Foundation (NSF) proposers and awardees. (May 5)
Office of Laboratory Animal Welfare
Office of Management and Budget (OMB)
  • RSP communication related to guidance on implementation of OMB Memo 20-26. (July 1)
  • OMB M-20-26 Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations (June 18, 2020) **Note that this memo grants authority to agencies to allow flexibilities, but it does not require them to provide flexibilities.
  • (RESCINDED 6/18/20) OMB M-20-20 Repurposing Existing Federal Financial Assistance Programs and Awards to Support the Emergency Response to the Novel Coronavirus – COVID-19 (April 10) **Note that this memo grants authority to agencies to allow flexibilities, but it does not require them to provide flexibilities.
  • (RESCINDED 6/18/20) OMB M-20-17 - Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations, issued March 19, 2020 **Note that this memo grants authority to agencies to allow flexibilities, but it does not require them to provide flexibilities.
  • RSP Summary of OMB Memo M-20-17 – Administrative relief for recipients and applicants of federal financial assistance directly impacted by the novel Coronavirus (COVID-19) due to loss of operations.
  • OMB Memo to Agency Heads - OMB Memo detailing administrative relief for recipients and applicants of federal financial assistance directly impacted by the Novel Coronavirus (COVID-19), issued March 9, 2020 **Note that this guidance is for Federal awards “that support the continued research and services necessary to carry out the emergency response related to COVID-19.”
Patient-Centered Outcomes Research Institute (PCORI)
SABIC Global Procurement
Space Telescope Science Institute
Spencer Foundation
Susan G. Komen
United States Department of Agriculture (USDA)
USAID
WI DNR Surface Water Grants Program
Wisconsin Department of Justice
World Health Organization
  • World Health Organization - Information and guidance from WHO regarding the current outbreak of Coronavirus Disease (COVID-19).

Frequently Asked Questions

Research Management and Development Related to COVID-19

Check federal agencies for funding opportunities related to COVID-19. InfoEd/SPIN has a library of COVID-19 funding opportunities at this site. Then start the conversation with your dean's office administrators to ensure you are considering various aspects of this type of research.

Contact the Office of Biological Safety if your work involves biological samples that may contain the virus (biosafety@fpm.wisc.edu, 608-263-2037). Contact the IRB if you want to do research with human subjects or biological samples that come from human subjects (asktheirb@hsirb.wisc.edu, 608-263-2368). Contact the RARC if you work involves animal models (help@rarc.wisc.edu, 608-262-1238).

Now is a good time to consider how an outbreak of COVID-19 in Wisconsin might affect your research. Here is a list of questions to get you started.

Here are a few simple scenarios in order to consider these impacts:

  • What would the impact be to your research and sponsored programs if you had to self-quarantine for two weeks?
  • What would the impact be to your research and sponsored programs if more than one of your research staff had to self-quarantine for two weeks?
  • What would the impact be to your research and sponsored programs if UW-Madison advised all faculty and staff to work remotely?

Here are additional questions to help you assess how an outbreak may affect your research:

  • Are there any studies involving participants, animals, ingredients, or experiments that would be adversely affected? If so, what plans should be put in place to allow for them to continue or allow for them to be stopped and later resumed in the least impactful way?
  • What standing purchase orders or human resource issues might be impacted?
  • Would data collection/analysis/storage be impacted and what costs would be associated with these impacts?
  • What regulatory approvals will expire soon and might be impacted if they are not renewed? Can they be renewed early?
  • Are there any collaborators that would need to be notified?
  • What sponsor reports or deadlines are due during the next several months? Might you need to request a no-cost extension?
  • What notice might you need to give sponsors or regulators if the research is going to be paused or significantly delayed beyond a couple of weeks?

Additional considerations for human subjects research:

  • Is the location of the study remaining open and available for participants to be present? Has the location implemented any procedures to slow the spread of the coronavirus that will affect participation in your study or the ability of your study to proceed?
  • Does your protocol require in-person participation or treatment? Can it be modified for remote participation?
  • Does your protocol require in-person monitoring? Can it be modified for remote monitoring?
  • Should your participants be screened for coronavirus as part of your inclusion/exclusion criteria?
  • Would your data or results be affected if your participants had to self-quarantine or if they contracted coronavirus?

Additional considerations for environmental health and safety:

  • Do you have a limited number of critical lab staff with unique knowledge? Are there others in your lab who can be cross-trained?
  • Does your lab operate machines that use active cooling through liquid gasses, dry boxes, or inert boxes using gas blankets? What would happen if materials like liquid gasses, CO2, nitrogen, or dry ice become unavailable?
  • How frequently are you saving or freezing samples of your cell cultures?
  • Do you have long-term experiments that might benefit from more frequent preservation?
  • Do you have the requisite local knowledge to do controlled shutdowns of complex machines or devices such as NMRs without on-site help from the company?
  • Have you shared with EHS the locations and amounts of materials that are air, water, or otherwise unstable for observation in case of lab closure?

Award Management Issues Related to COVID-19

Please also see the question “May I pay staff on new grants that were activated after the pandemic began, if work cannot be performed due to COVID-19?” below.

In most cases, yes but see the limitations below. UW-Madison has an updated leave policy available here: https://kb.wisc.edu/ohr/policies/page.php?id=98958. This is an institutional policy that applies to all employees, regardless of funding source. This is critical because the Uniform Guidance states that allowable costs must “(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.”

The updated leave policy outlines several different scenarios, including 1) continuing to work on campus as an essential employee; 2) working remotely as an essential or non-essential employee; 3) taking UW-Madison COVID-19 leave through May 15, 2020; 4) taking federal emergency leave; or 5) reassignment, leave without pay, and furlough options for employees who cannot work remotely or who do not have work to perform. If an employee is working (either on campus as an essential employee or remotely as an essential or non-essential employee), then the salary can continue to be charged with its current allocation, including to sponsored projects. If an employee is using leave time in accordance with University policy, then we will continue our practice of charging leave to the sources in place at the time the leave is taken.

Please note that the UW – Madison policy allows use of institutionally-granted COVID-19 leave through May 15, 2020. That limitation applies to sponsored projects as well. UW COVID-19 leave will not be available starting May 16, 2020. Although UW COVID-19 leave will no longer be available, UW-Madison employees who are affected by COVID-19 may qualify for paid leave under the federal program called the Families First Coronavirus Response Act. Please see Leave programs for employees affected by COVID-19 for more information. We strongly recommend working with your HR representative should you have any questions.

The Office of Management and Budget has authorized agencies to allow certain flexibilities, but agencies must explicitly allow recipients to exercise such flexibilities. (See RSP’s summary of OMB’s memo.) The flexibilities include the ability to continue charging salaries consistent with institutional policy regarding paying salaries under unexpected or extraordinary circumstances from all funding sources, both Federal and non-Federal. Not all agencies may grant such authority, and there may be non-Federal sponsors that do not offer similar flexibility. For information on agencies that have released guidance in accordance with OMB Memo M-20-17, please see this page. Regardless of the OMB guidance, we must comply with institutional policy, including the cessation of UW COVID-19 leave after May 15, 2020.

As you are all aware, the situation is developing rapidly and changing quickly. We hope all agencies grant these flexibilities. Irrespective of what an agency may implement, we will need for our departments to document how their operations are being impacted by COVID-19. We will also need to ensure that salary charges are aligned with institutional and sponsor policy.

We are treating salary charges for individuals who are working from home the same as salary charges for those who are quarantined but still performing work on the research project. See the FAQ “Am I allowed to pay staff who may be quarantined on sponsored funding?”

No. Salaries may not be charged for new awards where the work has not yet started and cannot be performed remotely. In order for salaries to be allowable on new awards, work must be able to be accomplished remotely or be an on-site activity approved by a dean or director.

All summer work performed by C-basis (9-month) faculty, academic staff, and limited appointees requires prior approval by the individual's appointing unit. Each summer is comprised of three months, referred to as “ninths.” See policy on summer appointments.

There are varying situations that factor into the ability to charge summer salary to a sponsored project. The sponsor’s guidelines, Federal regulations, and university policies underlie any determination. However, there are three broad categories that can be described:

  • If an individual is working on-campus or remotely and contributing to a sponsored project, salary can continue to be charged to the award.
  • If an individual cannot contribute to a specific sponsored project, but can work on another project or on institutional duties, the salary should be charged to the other project or to institutional funds, whichever is most appropriate for the activities.
    • Keep in mind that the sponsor’s prior approval requirements regarding a change in scope or objectives continue to apply. If someone wants to use award funds to work on objectives that are not aligned with the scope of the award, then sponsor prior approval must be obtained.
    • OMB Memorandum M-20-20 says that labor and supplies can be contributed to another project to support COVID-related activities. However, each Federal agency must implement that memorandum, so it is necessary to confirm the agency approach to the contribution of resources to another project. For example, prior approval is not required to divert faculty from research to clinical work related to COVID-19 until the end of the public health emergency period.
  • If an individual cannot work on-campus or remotely on any project, then salary cannot be charged to sponsored projects.

Discussions for making summer appointments for 2020 should not differ from those in the past. If an individual has funding to support salary through sponsored projects and has the ability to perform work on the projects, then the person’s salary may be charged to those sponsored projects over the summer.

Yes, recipients of a Vilas Associate Award can still receive July and August summer salary.

Yes, NIH indicated that stipend payments may continue to be charged. The Grants Management Specialist should be notified. Agency guidance on this is available at: https://grants.nih.gov/faqs#/covid-19.htm?anchor=question55770.

As a result of the COVID-19 pandemic, the current effort reporting period is being extended by one month. Therefore, July – December 2019 effort statements must be completed no later than May 31, 2020. See the announcement on RSP’s Effort page.

Sponsored project activities during the January – June 2020 effort reporting period may likely be impacted by the COVID-19 pandemic. Many Federal agencies and other sponsors have released guidance related to award management and the impacts of COVID-19. RSP will be reviewing this guidance and assessing its impact on our effort reporting processes. In the meantime, please continue to follow all relevant policies and procedures and apply those practices consistently. Our Effort Team will continue to update this FAQ as more information becomes available, in addition to sending out campus-wide messages.

Federal agencies have been granted the authority by the Office of Management and Budget to exercise certain flexibilities for grants and cooperative agreements. These include the ability to charge costs related to cancelled travel. For further information about agencies that have provided guidance on these types of costs, see this page. Additional guidance from both federal and nonfederal sponsors related to COVID-19 is available at this page, under Sponsor/Organization Updates. Please continue to follow all relevant policies and procedures and apply those practices consistently. Currently, per UW travel guidelines, as long as the circumstances were outside of the traveler’s control, fees for changing/cancelling flights are payable/reimbursable by the University (e.g. meeting dates changed). If the original expense was allocable to a sponsored project, the subsequent fees for changing/cancelling travel would also be allocable to that project.

Possibly, but not necessarily. The Office of Management and Budget has advised that recipients should not assume that additional funds will be available. Researchers may be able to request supplemental funding, but there is no guarantee that such funds will be awarded. We expect that federal agencies will recognize the difficulties inherent in this situation and work with institutions to facilitate the conduct of the project.

OMB Memo M-20-20 authorizes federal agencies to allow recipients to donate personal protective equipment and other resources to support COVID-19 emergency response activities. In general, please check sponsor guidance related to the award on which the items were originally purchased. Please be aware that sponsors may make a distinction between transfers of materials between UW departments/units and donations to external organizations (e.g., hospitals, clinics, non-profits, etc.).

The National Institutes of Health has indicated that this may be done without needing to seek NIH prior approval. See the NIH FAQ under Costs/Prior Approvals. The National Science Foundation, however, has requested that grantees contact their NSF program officers prior to taking such action. See the NSF implementation of M-20-20. Other agencies’ guidance may not yet be available. In all cases, whether the materials are considered shared or donated, please document and track the supplies.

Additional guidance on PPE and reagents has been provided in the UW-Madison COVID-19 FAQs on Research, specifically under “Can I still conduct my on-campus research?” and “How can UW-Madison research labs assist with the COVID-19 response?” The guidance includes the following:

There are shortages of critical personal protective equipment (PPE) around the world, especially N95 respirators, Tyvek suits, isolation gowns and procedure masks. Labs are being asked to conserve their PPE and share it with those in need, as identified by the Emergency Operations Center Logistics Team. If you have extra PPE you would like to donate, or if you need these items for essential operations and have a request in that is currently unmet, contact the EOC Logistics Team at EOC_PPE_Supplies@lists.wisc.edu. All PPE use requests will be evaluated for need, application of equipment alternatives, and for measures that can be taken to reduce PPE consumption.

Also, related to reagents and other supplies that could be used by the State Lab of Hygiene for testing for COVID-19:

If you think you can help, please contact: Pete Shult, peter.shult@slh.wisc.edu, 608-224-4328 or 608-262-5419 | Alana Sterkel, alana.sterkel@slh.wisc.edu, 608-224-4277 | Allen Bateman, allen.bateman@slh.wisc.edu, 608-224-4254

For sponsored projects, outfitting a home workstation is generally an unallowable cost. The classification of direct cost versus indirect cost remains the same. Direct costs are clearly identified with a project’s activities and objectives. Indirect costs are not directly related to a specific sponsored project and are incurred for common or joint objectives. Indirect costs typically include office supplies or furniture and should be charged to non-sponsored funding. Additionally, Business Services has offered the following guidance related to small office purchases on non-sponsored funding: https://businessservices.wisc.edu/procurement-purchasing/purchasing-low-dollar-office-supplies-while-telecommuting/

Business Services has made guidance available about use of these codes. Please see the COVID-19 Account Codes FAQs on their website.

Click here to read special COVID-19 routing instructions for checks related to sponsored programs.

COGR's FAQs Regarding COVID-19's Impact on Federal Awards

COGR is an association of leading research universities, affiliated medical centers, and independent research institutes. COGR convenes experts in the field and provides analysis of current issues in research administration and compliance. UW-Madison is a COGR member institution and looks to COGR for information to help guide our institution.

Important Note from COGR: The information provided herein has not been endorsed by federal awarding agencies and represents COGR’s best assessment of an evolving situation based on already established policies and regulations. As further guidance becomes available from federal agencies COGR will update this document and keep the membership informed accordingly. Nothing in this document is intended to supplant any institutional policy or federal, state, and local law, regulations, or guidance, and institutions are strongly encouraged to communicate with their agency program officers and grant officers as issues arise.

Full list of questions is posted below. Click here for full document with answers.

Travel Charges, Including Cancellation Costs

  • How should credits from cancelled travel costs be handled on sponsored projects?
  • What do you know about accommodations airlines are making because of COVID-19?
  • If a traveler can return home from travel (domestic or foreign) but at much greater cost than usual, is the additional cost allowable on the grant?
  • Can travel insurance be charged to grants?
  • I am a PI on a very large Program Project Grant, which includes hosting a conference in Atlanta with hundreds of collaborators participating from around the world. I have already incurred $35,000 of expense for the rental space at the convention center and hotel. I am working with the venue to get a credit but there will be a sizeable cancellation or penalty fee. Can I charge this to my award? And can I pay the travel fees and any associated costs for the hundreds of collaborations that were planning on attending?

Remote Work Environments

  • If my institution’s labs are closed and researchers cannot get to special or core facilities, how will they continue to work?
  • If employees must have their home as their work location, will they still be able to get paid by grants? Specifically, if they usually are supervised, or punch in and out, etc., could we be called to task for suspending such oversight while allowing the work to continue?
  • What happens if local, state, and/or federal government employees are unavailable to perform their duties (e.g., issue prior approvals or process awards)?
  • If a student or a researcher needs to access a data set from home in order to keep working on a project, how do we address privacy requirements, if the data set contains sensitive or private information?
  • What happens if local, state, and/or federal government employees are unavailable to perform their duties (e.g., issue prior approvals or process awards)?

Project Progress Obligations

  • Where a research project has a strict timeline, we are concerned about a possible failure to perform within the agreed upon statement of work. This failure may be due to a slow down or gap in activities, particularly where staff may need to work from home.
  • Will agencies consider longer no-cost time extensions if they are needed to finish a project after disruption?
  • I can’t get to my research site and my research will be severely impacted. Will the sponsor provide incremental funding and/or additional time so that I can successfully complete the aims of the award?

Salary Charges

  • On March 19, the State Department issued a travel advisory raising all countries outside of the U.S. to a Level -4 “Do Not Travel” status. If a researcher chooses to travel abroad (e.g., to fulfill a grant responsibility such as present a paper or attend a meeting to discuss research) although his/her institution has advised against travel to that country, can salary still be charged to the award – even if they need to stay in the country longer than originally anticipated?
  • Can salary continue to be charged if a researcher is on multi-day self-isolation period? Does it matter if the researcher is able to continue to work on the project from the self-isolation site (e.g. home or designated facility) or is not able to work (e.g., because the work must be done in a wet lab or field site?). Does it matter whether the self-isolation is self-imposed, institution-imposed, or government-imposed?
  • If schools or elder-care facilities close, can award-funded employees stay at home to do child-care and elder- care and still charge their salary to a grant?
  • If the agency program officer or grants officer is unavailable (or if the agency is closed) due to COVID-19, can grant personnel continue to work and charge salary to the project?

Purchase of COVID-19 Related Items on Grants

  • Research studies with a lab component already purchased gloves. Who would pay for other supplies (masks, wipes, etc.), if needed?

Additional Cost Considerations

  • What happens to tuition payments on sponsored programs if the semester is affected by partial or complete shutdowns?

Animals and Human Subjects

  • If staff would need to work from home, we are considering cell phones for use when contacting human subjects since some people are uncomfortable with using their personal phones when calling human subjects or research study participants. Depending on the research study, it could be from one to three to several cell phones needed. What alternatives do they have?
  • Reminder calls to research study participants to stay home if they are sick are already taking place. Some of our research study participants are older and more vulnerable. Emails from my institution have reminded employees to stay home if sick. Can I charge unexpected costs that may arise to the grant? (For example, additional labor charges for time spent calling study participants).
  • The government’s declaration of a public health emergency is causing our institution to evaluate which clinical trials to continue and which to pause temporarily. We are also concerned about potential delays in research when studies are paused and the potential for additional costs. What guidance is available on this topic to help with institutional decision making?
  • We had planned an animal facility inspection that cannot go forward as scheduled due to institution policies to close certain research activities. How should we inform the appropriate authorities?
  • We are engaged in NIH funded behavioral studies that require our subject to visit our testing lab (mainly doing computer exercise while being observed). Our university is reducing the number of people on campus, including sending students home. Should we bring subjects (children and their parents) to our lab?
  • My IRB/IACUC is not able to process my protocol or protocol continuation. May I proceed anyway?
  • I have lab animals that need to be cared for and am concerned that staff may not be available to care for the animals or have the access they need to facilities if my institution closes.

Additional Questions

  • If I have a proposal due and my institution closes, will the awarding agency still accept my application?
  • For all of the above, are the answers any different by sponsor?
  • Is there a difference if the award mechanism is a contract as opposed to a grant?
  • Are disruptions to federal payment systems or payments anticipated?