Executive Office Of The President Office Of Management And Budget Updates to OMB’s M-20-11 and M-20-17
On March 9, 2020, OMB issued a Memorandum to the Heads of Executive Departments and Agencies pertaining to Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19).
On March 19, 2020, OMB issued a Memorandum to the Heads of Executive Departments and Agencies pertaining to Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations.
Listed below are the highlights from each memorandum. There is significant impact on the protection of operation and funding caused by COVID-19 for federally funded tribal entities, including the NLC.
Expenditute of Award Funds for Salaries and Other Project Activities
Awarding agencies may allow recipients to continue to charge salaries and benefits to currently active federal awards consistent with the recipient organization’s policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal. Agencies may allow other costs to be charged to federal awards, including those necessary to resume activities supported by the award, consistent with applicable federal cost principles and the benefit of the project. Federal agencies may also evaluate the recipient’s ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances, based on subsequent progress reports and other communications with the recipient.
Exemption of Certain Procurement Requirements
Awarding agencies may waive the procurement requirements contained in 2 CFR 200.319(b) regarding geographical preferences and 200.321 regarding contracting with small and minority businesses, women’s business enterprises, and labor surplus firms.
Extension of Financial and Other Reporting
Awarding agencies may allow recipients to delay submission of financial and other reports up to three (3) months beyond the normal due date. If an agency allows such a delay, recipients will continue to draw down federal funds without the timely submission of these reports. However, these reports must be submitted at the end of the postponed period.
Extension of the Single Audit Submission
Awarding agencies should allow grantees to delay the completion and submission of the Single Audit report as required under Subpart F of 2 CFR 200 to twelve (12) months beyond the normal due date.
Allowability Salaries and Other Project Activities (2 CFR 200.403, 2 CFR 200404, and 2 CFR 200.405) – Continuation to the similar section in OMB M-20-11
Awarding agencies must require recipients 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 activity costs related to interruption of operations or services.
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 and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to public health emergency, to charge these costs to their award without regard to 2 CFR 200.403 Factors Affecting Allowability of Costs, 2 CFR 200.404 Reasonable Costs, and 2 CFR 200405 Allowable Costs. Awarding agencies must require recipients 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 cancellation or other fees related to interruption of operation or services.