Last updated: March 31

OMB Guidance to Federal Agencies

OMB guidance to federal agencies (PDF)

Guidance from Sponsored Projects Accounting (SPA)

Travel Cancellation Costs

National Institutes for Health (NIH):

The NIH has provided additional flexibility for travel costs related to COVID-19 via NIH Guide Notice NOT-OD-20-86:

  • Non-refundable costs associated with grant-related travel that has been cancelled due to COVID-19 may be charged to the NIH award if they would have otherwise been allowable.
  • Non-refundable registration fees for conferences, symposiums or seminars that have been cancelled due to COVID19 may be charged to the NIH award if they would have otherwise been allowable (e.g. necessary to accomplish program objectives).

National Science Foundation (NSF):

The NSF has also addressed this issue in their guidance document issued on 3/23/20:

  • 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 the public health emergency, are authorized to charge these costs to their award.

Department of Defense (DOD):

Per the DOD’s frequently asked questions document issued on 3/24/20:

  • The DOD will allow nonrefundable travel expenses incurred for travel canceled due to COVID-19 to be charged to active awards in agreement with OMB Memorandum M-20-17.  Grantees must follow applicable institution policy on allowable expenses for travel.

Centers for Disease Control (CDC):

Per the CDC’s frequently asked questions document issued on 3/23/20:

  • CDC can allow recipients to charge costs to the award such as the cancellation of events, travel, or the pausing and restarting of grant-funded activities due to the public health emergency. Recipients are required to maintain records and documentation to substantiate the cost.

Other Federal Agencies:

Additional guidance from other Federal agencies will continue to be issued and/or updated. It is likely that the other federal agencies will provide costing flexibility similar to the NIH’s and NSF’s statements.    SPA suggests that reimbursement requests and/or accounting adjustment should be held until agency specific guidance is issued.

Non-federal Agencies:

In general, non-federal grants provide more flexibility and discretion for costing issues. Please contact with specific questions regarding non-refundable costs associated with non-federal sponsored projects.

Refund checks related to trip cancellations should be deposited/posted to the sponsored fund(s) that incurred the initial cost.

Refund checks related to trip cancellations should be deposited/posted to the sponsored fund(s) that incurred the initial cost.

American (3/12/20) – Waive one-time change fee for all new non-refundable tickets purchased between March 1 and March 31, 2020. Click here for more details.

Delta (updated 3/10/20) – Waiving change fees for all flights during March 1 – April 30, no change fees for all tickets purchased between March 1 – 31st and certain other international flights beyond that time. See https://www.delta.com/us/en/advisories/other-alerts/coronavirus-travel-updates

United (3/12/20) – Waiving change fees for all flights between March 3 – 31st and also waiving change fees for all tickets issued on or before March 2 — domestic or international — with original travel dates of March 9 through April 30. A comprehensive table of waived change fees for specific airports/periods of travel is available at https://www.united.com/ual/en/us/fly/travel/notices.html

Salary Charges

Salaries for faculty, staff and students working on sponsored projects from a remote location may be charged to the applicable sponsored funds.

Individuals working remotely due to self-imposed, University-imposed or Government-imposed isolation can continue to charge salary to sponsored funds as long as they remain engaged in the project.

If an individual cannot contribute to their current project but can contribute to another sponsored project or school activity, the salary should be moved to that funding source.  

Individuals who are unable to perform their regular duties due to the effects of the COVID-19 will be provided with up to ten paid days away from work without affecting their sick or vacation balances.  This Special Time Off can be charged to sponsored funds and complies with the specific guidance issued by both the National Institutes of Health, the National Science Foundation, the Department of Defense and the Centers for Disease Control and Prevention (see below).

National Institutes for Health (3/12/20):

  • NIH understands that many researchers may be unable to work as a result of or related to the effects of COVID-19. If a recipient organization’s policy allows for the charging of salaries and benefits during periods when no work is performed due to the effect of COVID-19, regardless of the funding source, including Federal and non-Federal, then such charges to NIH grant awards will be allowable.

National Science Foundation (10/23/20):

  • Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active NSF awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. The recipient also is authorized to charge other costs to NSF awards that are necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. Recipients must not assume that supplemental funding will be available should the charging of such costs or other fees result in a shortage of funds to eventually carry out the project.

Department of Defenses (3/24/20):

  • The DOD will allow recipients to continue to charge salaries and benefits to currently-active awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal.  DOD components may allow other costs to be charged to federal awards necessary to continue work on a project even if in a period where primary research activities are limited or curtailed.  To the maximum extent practicable, recipients will be expected to invoke or institute any and all reasonable mitigation actions and practices to lessen the cost to the government during the crisis period

Centers for Disease Control and Prevention (3/23/20):

  • Recipients may continue to charge salaries and benefits to currently active federal awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources. Recipients are required to maintain records and documentation to substantiate the cost, including reference to the recipients’ salary policy. Concurrent with programs, recipients will need to assess the impact on their programmatic activities that were originally funded once normal activities resume as there is no guarantee of additional funding.

National Aeronautics and Space Administration (3/30/20):

  • Universities may allow the payment of soft-money researchers using NASA grant funds, as well as graduate students, post-docs, and other lab staff during the COVID-19 epidemic if the institution’s policies allow it.
  • Recipients are authorized 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. The recipient must also document and maintain records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services.

Other Costing Issues

Office supply items that may be needed to work from remote locations (e.g., pens, paper, notebooks, printers, toner…) are considered administrative costs and cannot be charged directly to sponsored funds.

No Cost Extensions

Will agencies consider longer no cost time extensions if needed to finish a project after disruption?

Researchers should document the actual impact of COVID-19 on the progress of their grants to provide substantiation for any future no cost time extension request. It is not known at this time if agencies will consider longer-than-normal no cost time extensions, or multiple no-cost time extensions, in this situation, but standard no-cost time extensions will still be available.