OMB Guidance in Response to COVID-19

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On March 19, the Office of Management and Budget (OMB) issued memorandum M-20-17, Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations. The memorandum provides temporary relief for federal award recipients and subrecipients impacted by the COVID-19 pandemic.

The memorandum summarizes 13 areas of administrative relief, which include the following:

  • Flexibility with application deadlines (2 CFR § 200.202) - Awarding agencies may provide flexibility with regard to the submission of competing applications in response to specific announcements, as well as unsolicited applications. As appropriate, agencies should list specific guidance on their websites and/or provide a point of contact for an agency program official.
  • Extension of currently approved indirect cost rates (2 CFR § 200.414 (c)) - Awarding agencies may allow grantees to continue to use the currently approved indirect cost rates (i.e., predetermined, fixed or provisional rates) to recover their indirect costs on federal awards. Agencies may approve grantee requests for an extension on the use of the current rates for one additional year without submission of an indirect cost proposal. Agencies may also approve grantee requests for an extension of the indirect cost rate proposal submission to finalize the current rates and establish future rates.
  • Extension of Single Audit submission (2 CFR § 200.512) - Awarding agencies, in their capacity as cognizant or oversight agencies for audit, should allow federal award recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse, as of March 19, 2020, that have fiscal year-ends through June 30, 2020, to delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501 – Audit Requirements, to six months beyond the normal due date. No further action is required by the awarding agencies to enact this extension. This extension also does not require individual federal award recipients and subrecipients to request approval for the extension by the cognizant or oversight agency for audit; however, federal award recipients and subrecipients should maintain documentation of the for the delayed filing. Under the criteria of 2 CFR § 200.520 (a) – Criteria of a low-risk auditee, federal award recipients and subrecipients taking advantage of this extension would remain qualified as a “low-risk auditee.”

You can access the full memorandum here. While the memo offers welcomed concessions, the situation is fluid, and additional actions may become necessary. As such, it is important to monitor further guidance from the OMB.

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