The administrative flexibilities extended to federal agencies through the Office of Management and Budget’s Memo M-20-17 is set to expire on June 17, 2020. In preparation, please find attached to this communication two updated Frequent Asked Questions (FAQs) addressing the following issues:
As a result of these FAQs, the university research administration offices are providing the following guidance to divisional business officers, faculty, and department administrators:
1. Salaries charged to sponsored awards. Beginning June 16, 2020 salaries for personnel who are unable to work at all may not be charged to sponsored awards. Any salary charges for personnel who are unable to work that are charged to grants after June 15, 2020 must be transferred off those awards. Personnel who are still able to work remotely or in other capacities may continue to have their salaries charged to sponsored awards, commensurate with their ability to perform work on these awards.
2. Change to temporary pay policy. The University’s temporary pay policy ends on June 15, 2020. Starting June 16, 2020, divisional business officers may continue to pay personnel who may no longer be charged to grants; however, these salary expenses must be charged to non-sponsored accounts. Divisions should consult their assigned human resources contacts for questions about particular staff members.
3. E210 tracking for personnel who are unable to work. Any personnel who are unable to work at all must record their status in the E210 system using the appropriate COVID-19 codes.
4. Faculty who remain unable to work. Investigators who remain unable to perform any work on their sponsored projects must notify their appropriate research administration office of their status to determine the required next steps.
5. Additional OMB administrative flexibilities to awards recipients. In the event that any of the additional flexibilities are extended, further guidance will follow.
Please contact your research administration office for any questions you may have. For additional JHU Policy FAQs and Research Administration Guidance, visit this page.
Published: June 11, 2020
Previous related announcements are posted below in chronological order.
Published: May 26, 2020
This notice is in follow-up to the research administration guidance regarding COVID-19 agency flexibilities extended to applicants and grantees. The NIH has again updated their guidance on COVID-19 flexibilities. In light of the recent update, the University Research Administration offices (JHURA/SOM ORA,/BARA) are offering the following revised guidance to JHU faculty.
1. Salaries charged to sponsored awards. Researchers are encouraged to continue to work on their projects to the extent possible, using telework and other methods consistent with the current restrictions. Under existing OMB guidelines, which are in effect until June 15, 2020, personnel who are budgeted to a grant, but cannot perform work on the grant because of COVID-19 restrictions, may continue to be charged consistent with this current JHU statement on the JHU COVID-19 Hub site. In these cases where researchers are not able to carry out any work on their sponsored projects, faculty must notify their applicable Research Administration office (JHURA/SOM ORA/BARA). The Research Administration offices will facilitate notifications to the applicable funding agency program officers and the University Financial Research Compliance office. In addition, NIH has indicated that researchers must report adverse effects resulting from the COVID-19 pandemic on the conduct of NIH funded research in the RPPR’s that are due within the next 90 days. Understanding that there may have been delays in the progress of the project, when preparing the RPPR, investigators should outline details related to the disruptions to the research efforts. NIH has stated that they remain committed to working with recipients and will consider the effects that are reported by the recipient when reviewing and approving the RPPR, including any delays in the submissions of RPPRs and other reports. See NOT-OD-20-086 for details on late submission. Please work with your applicable research administration office when submitting your RPPR.
2. Salaries charged to new sponsored awards. The NIH has stated that recipients may not initiate charges for salaries and benefits on new awards where the work has not yet started because of COVID restrictions, unless the performance can commence immediately (i.e. COVID research taking place on campus) or if the project can begin progressing via telework.
3. Foreign Component. For post-docs that returned to, or were unable to return from a foreign country due to COVID-19 travel restrictions, but are working remotely from that site, where no grant funds are going to a foreign entity, NIH has determined that this scenario does not constitute the performance of a significant scientific element or segment of the project outside the US, as outlined in the NIH Grants Policy Statement definition of a foreign component. You do not need to seek approval for a foreign component in such cases.
As a general reminder, researchers should be monitoring activity on research projects, and ensuring that personnel are accurately recording in the E210 when they are not able to work. For purposes of progress reports, applications for administrative supplements, and extensions, principal investigators should be tracking and documenting additional costs resulting from COVID-19 disruption and the impact it has had on the project.
We will continue to update you on any COVID-related guidance as we receive it. Please contact your Research Administration office for any additional questions you may have.