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OSP FAQ: Pre-Award

Frequently Asked Questions (FAQs)

These FAQs are for federal and non-federal grants. Some federal agencies are not adopting flexibilities allowed by OMB M-20-17 for specific award mechanisms, such as contracts or fixed price agreements. Please check sponsor specific guidance for clarification.

Proposal Submission and Award Management

Will my proposal still be submitted to the sponsor on time amid a COVID-19 outbreak?

At present, proposals are being submitted by the Office of Sponsored Programs (OSP) according to UMMS’s internal proposal submission deadline policy. OSP will ensure proposals will be submitted amid the COVID-19 situation by having staff work remotely.

Will my proposal still be submitted to the federal government on time if the federal agency to which I intend to apply is closed due to a COVID-19 outbreak?

At present, all federal agencies are accepting proposal submissions as usual. In the event a COVID-19 outbreak closes a federal agency that is currently accepting proposals, we expect the agency will continue to accept proposals; however, the proposals will most likely remain in a queue (e.g., within the Grants.gov system), pending resumption of agency operations – as has been the case during recent federal budget-related shutdowns.

The Council on Governmental Relations (COGR) developed a webpage that features comprehensive links to key federal agencies' COVID-19 operations.

How can I reach GCA amid a COVID-19 outbreak?

OSP and GA employees are working remotely and will respond to emails and monitor phone calls as normal.

As it relates to research grants, how does the National Institutes of Health respond to natural disasters and other emergencies?

With respect to proposal submissions, on March 26, 2020, NIH published the following notice:

UPDATE: NIH Late Application Policy Due to Public Health Emergency for United States for 2019 Novel Coronavirus (COVID-19) NOT-OD-20-091

  • All grant applications submitted late for due dates between March 9, 2020 and May 1, 2020, will be accepted through May 1, 2020.  
  • This notice applies to all relevant funding opportunity announcements, including those that indicate no late applications will be accepted. 
  • Institutions need not request advance permission to submit late due to this declared emergency and a cover letter providing a justification is not required.
  • For Funding Opportunity Announcements that expire prior to May 1, 2020, NIH will extend the expiration date for 90 days to accommodate the submission of late applications and grants.gov will be adjusted to allow NIH to receive applications.
  • Applicants should assume that late applications submitted after May 1 may not be reviewed until meetings for the January 2021 council round (e.g., October-November 2020).

On March 10, 2020, NIH also published the following notice related to COVID-19:

General Frequently Asked Questions (FAQs) - Proposal Submission and Award Management Related to COVID-19 NOT-OD-20-083

“This Guide Notice intends to address general questions associated with proposal submission and award management that may arise in relation to COVID-19. NIH is providing this information as a service to our applicant and recipient communities in the hopes it will address high-level questions that may arise in this regard. Please note that given the fact that COVID-19 and associated impacts continue to evolve, applicants and recipients are strongly encouraged to monitor this website for updates. NIH intends to publish detailed guidance related to administrative flexibilities and associated FAQs.”

On March 12-13, 2020, NIH published the following notice and FAQ related to COVID-19:

Flexibilities Available to Applicants and Recipients of Federal Financial Assistance Affected by COVID-19​​ NOT-OD-20-086

The NIH-funded UMMS research community is strongly encouraged to read this NIH notice, which provides a number of important flexibilities for managing NIH awards during this public health emergency. Highlights include:

  • Expanded use of allowable pre-award costs
  • Extended due dates for Financial and Other Reporting (e.g. RPPRs)
  • Waiver of certain prior approval requirements
  • Allowance of certain costs that would normally not be allowable (e.g., stipends, salaries and benefits when no work is being performed on the project, cancelled travel costs, etc.)

NIH maintains the following webpage:

Frequently Asked Questions (FAQs): COVID-19 Flexibilities

This document provides clarifying answers surrounding the newly authorized flexibilities, particularly with respect to:

  • ​Application Submission
  • Delays in Research Progress
  • Financial and Performance Reporting (RPPR)
  • Costs

What if a NIH-funded project requires an immediate change that affects the outcomes or trajectory of a clinical trial or human subjects research protocol? Do the changes need to be approved by the program officer?

If you need to make changes because of safety, that’s top priority. The first administrative authority would be IRB. Do what you need to do. Then please get in contact with your program officer. Please don’t let administrative concerns with the agency get in the way of public health or patient safety.

As it relates to research grants, how does the National Science Foundation respond to natural disasters and other emergencies?

Per NSF’s Proposal and Awards Policies and Procedures Guide:

“In the event of a natural or anthropogenic disaster, or when NSF is closed due to inclement weather or other reason that interferes with an organization’s ability to meet a proposal submission deadline, NSF has developed the following guidelines for use by impacted organizations.”

  • Natural or Anthropogenic Disasters: Flexibility in meeting announced deadline dates because of a natural or anthropogenic disaster that impacts a proposer’s ability to submit a proposal to NSF may be granted with the approval of the cognizant NSF Program Officer. Where possible, such requests should be submitted in advance of the proposal deadline. Proposers should contact the cognizant NSF Program Officer in the Division/Office to which they intend to submit their proposal and request authorization to submit a proposal after the deadline date. Proposers should then follow the written or verbal guidance provided by the cognizant NSF Program Officer. The Foundation will work with each impacted organization on a case-by-case basis to address its specific issue(s). Generally, NSF permits extension of the deadline by up to five business days.
  • To submit the proposal after the deadline date, proposers must check the “Special Exception to the Deadline Date Policy” box on the NSF Cover Sheet, indicating NSF approval has been obtained. A statement identifying the nature of the event that impacted the ability to submit the proposal on time should be uploaded under Nature of Natural or Anthropogenic event in the Single Copy Document section in FastLane. If available, written approval from the cognizant NSF Program Officer also should be uploaded under the Additional Single Copy Documents in the Single Copy Document section in FastLane.
  • Closure of NSF: When NSF is closed due to inclement weather or other reason, deadline(s) that occurred during the closure automatically will be extended to the following business day after the closure ends.

NSF recently developed a webpage for the research community with detailed guidance regarding COVID-19. This includes guidance for awardee organizations, researchers and reviewers of NSF proposals. 

Is there a formal process for notifying sponsors about the pause in human subject’s interactions if it applies to us?

The determination of whether a sponsor must be notified about the pause in human subject’s interactions, and the process for providing said notice, will vary by sponsor and the terms and conditions specific to the award document in question. Please familiarize yourself with the requirements of your award agreements and, if after having done so you still have questions, contact OSP.

Will requests for no-cost extensions on projects need to be run through OSP?

Yes.

How might we have to proceed with grants and contracts from industry, foundations and other nonfederal entities in regard to changes in costs or expected outcomes? 

Due to the heterogeneity of nonfederal sponsors, it is not easy to make a blanket statement. We advise following the general principles from federal grants (e.g., if a cost wasn't allowable on the grant in regular times, it likely won't be allowable now), but more specific issues around effects of timelines on nonfederal projects will likely have to be discussed with the sponsor. If the terms of the award need to be amended, OSP personnel are available to help through this process and discussions.

Is OSP changing any of its business processes given the fact that many sponsors are reaching out to support UMMS research related to COVID-19 or are publishing relevant funding opportunities with very short turnaround times?

All investigators who wish to carry out new or modified research projects related to COVID-19 must submit a request to the Dean with information about the nature of the work and the names of the essential personnel working on the project.

OSP will prioritize the submission of any proposal related to COVID-19. To ensure your document is prioritized accordingly, include “COVID-19” in the title of Proposal Routing Form and alert OSP by phone or e-mail.

OSP also will prioritize the negotiation of any projects related to COVID-19.

Can you summarize which federal agencies have made major changes in proposal submission and award management policies in response to the COVID-19 outbreak?

See the chart below for how various federal agencies’ have implemented policies that are consistent with the authorities granted to them under OMB Memorandum M-20-17.

Agency 

(as of)

Late proposal submission consideration

Waived prior approval requirements

Charging salaries of idled staff

Charging travel cancelation fees 

Shortened non- competitive renewals

Automatic no-cost extensions

Delayed progress and financial reports

NIH (link is external)

(3/19/20)

Yes

Yes

Yes*

Yes

No

Yes

Yes

NSF (link is external)

(3/23/20)

Yes

No

Yes*

Yes

No

No

Yes

DOD (link is external)

(3/24/20)

Yes

No

Yes*

Yes

No

Yes

Yes

CDC (link is external)

(3/23/20)

Yes

Uncertain

Yes*

Yes

Uncertain

Uncertain

Uncertain

SAMHSA (link is external)

(3/24/20)

No

No

Yes

Yes

No

No

Yes

DOJ/OJP

(3/21/20)

No

No

Yes*

Yes

No

No

Yes

USDA

(3/19/20)

No

No

No

No

No

No

No