COVID-19: Information from SPA/OSP/CGA

This webpage includes information specific to topics within SPA/OSP/CGA’s responsibilities.  Please also see information related to MSU research from the Office of Research and Innovation at:  https://vp.research.msu.edu/coronavirus. The list of agencies under the Agency Guidance section includes the agencies that MSU frequently works with, in approximate order of relevance.

SPA/OSP/CGA Communications

• October 8, 2020: "Cost-related flexibilities for expenditure of federal sponsored award funds related to COVID-19 have ended" SPA/OSP/CGA Listserv email

• August 5, 2020: "Cost-related flexibilities for expenditure of sponsored award funds" SPA/OSP/CGA Listserv email

• May 22, 2020:  Memorandum to faculty about Sponsored Programs COVID-19 Related Impacts/Changes - Provides insights and advice on managing various project situations and communicating with sponsors.

• April 14, 2020: Communication with Sponsors on Changes to the Scope of Work or Timeline for the Project

Proposal Deadlines

We anticipate that OSP will continue to have the ability to submit proposals, even while personnel are working remotely.  Our experience is that several federal agencies tend to be flexible about deadlines under difficult circumstances beyond our control.  If agencies are officially closed, proposals will most likely remain in a queue, pending resumption of agency operations – as has been the case during federal budget-related shutdowns.  Agency specific guidance is provided below.  When communicating with OSP please use group email addresses.

COVID-19 Funding Opportunities

For agency funding opportunities related to COVID-19 please visit the OR&I COVID-19 Research Funding Opportunities webpage.

Cost Related Flexibilities/Expenditure of Award Funds

The following provides guidance on cost/expenditure flexibilities that may be available for MSU sponsored programs. Please note that federal guidance on COVID-19 continues to evolve and more changes are anticipated.

Salaries:

MSU recognizes that work on sponsored programs has continued, e.g., much of the work can be performed remotely¹, some areas remained open throughout the Stay Home, Stay Safe Orders and many laboratories have been re-opened in accordance with building and lab plans.  When work is being performed, salary charges should continue to be allocated based on project benefit in accordance with the Federal/State Cost Policy and the Basic Cost Principles, and the applicable university policies.

Due to the additional requirements of OMB Memo M-20-26, when an employee is unable to perform work at the level of effort for which they are paid on a federally-funded sponsored program account (RC), it may be necessary to identify a different source of funding for the idle effort or consider other options.

• Salary charges for idle effort may be appropriate, subject to specific agency implementation, if the following conditions apply:
  • Continued salary is required by terms of employment, e.g., offer letter, union agreement, leave hours per MSU or Federal policy, or continued employment is needed for project commitments, and
  • Unrestricted funds are not available to cover the costs of the idle time.  In those cases, a justification for the pay on the sponsored program account should be documented and retained by the unit, including the following:
    • An explanation of how the pay is consistent with MSU policy.  Please consider that MSU has instituted some support staff furloughs for roles where work is not currently needed or cannot be completed remotely and that leaves such as eFMLA and EPSL may be allowable costs (leave information is available through Human Resources).
    • A description of why other sources of funding are not available to be used.  For instance, can the investigator/project director reallocate to other sources of support, such as gift funds or unrestricted resources? If not, document why not.

Operational costs:

Given the limited resources by both the university and the federal government, projects should reduce costs where possible and spend funding prudently in support of project objectives.

Travel:

Only travel that is essential to the project’s objectives should be considered. Essential project travel must be submitted for University approval through the normal process. Inclusion of travel in the project budget will not be a consideration for the University when reviewing for approval, but an explanation of how the travel is essential to the completion of the scope of work will be considered. Please be aware of your award’s travel restrictions (i.e. prior agency approval) prior to submitting travel for University approval.

As large gatherings pose a risk of spreading the virus, many organizations/sponsors are taking precautionary measures and cancelling conferences and events. Please refer to MSU’s guidelines for travel impacted by COVID-19 for guidance on cancelling any scheduled travel arrangements and requesting refunds.

Background on flexibilities: 

Consistent with guidance shared by the Office of Management and Budget through Memo M-20-17 and extended by Memo M-20-26, salary may be appropriate to be allocated to projects based on effort and the planned distribution, when it is consistent with MSU policy on all sources of funds and subject to sponsor direction.  The additional flexibilities are offered through September 30, 2020.  An excerpt from the OMB Memos follows:

Salaries:

Awarding agencies may allow recipients to 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, Federal and non-Federal.

OMB added additional requirements in Memo M-20-26, effective June 17, 2020 specifically stating:

Due to the limited funding resources under each federal award to achieve its specific public program goals, awarding agencies must inform recipients to exhaust other available funding sources to sustain its workforce and implement necessary steps to save overall operational costs . . . during this pandemic period in order to preserve Federal funds for the ramp-up effort.  Recipients should retain documentation of their efforts to exhaust other funding sources and reduce overall operational costs.

Non-Federal sponsors may have different requirements and additional advice can be accessed through:  https://osp.msu.edu/PL/Portal/1863/May222020SponsoredProgramsCOVID-19RelatedImpactsChanges

¹ For a description of many tasks that can be completed remotely, please see:  https://osp.msu.edu/PL/Portal/1863/May222020SponsoredProgramsCOVID-19RelatedImpactsChanges#Bestpractices

No-Cost Extensions

If you expect that you will need a no-cost extension and are within four to six months of the end date of your project, please submit your request to the CGA Awards group as soon as possible.  We are anticipating potential delays.  The sooner you submit your request, the less likely there will be a disruption to the project.

Communicating with Sponsors

Generally, if changes to the timeline or statement of work are needed, some communication with sponsors is likely appropriate.  More detailed information on communicating with sponsors by type of funding is provided in the 5/22 memo to faculty.  Communicate the potential impacts and requested resolution to the Contract and Grant Administration (CGA) Awards Group via email as soon as practicable, at awards@cga.msu.edu.  The Awards Group will review your specific scenario and work with you on next steps.

Agency Guidance Regarding COVID-19

Some Federal agencies, as well as the Council on Governmental Relations (COGR) and the Association of Public & Land-Grant Universities (APLU) have started providing guidance on the impacts of COVID-19 on proposals and awards.  Below is a list of resources by agency/group.