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Can EPA grant recipients continue to compensate employees whose work on EPA financial assistance agreements has been interrupted due to the impact of COVID-19?

Not without a regulatory exception. This flexibility provided in the June 18, 2020 OMB Guidance (PDF) was time limited and expired on September 30, 2020. Therefore,  EPA will consider providing exceptions to the regulations on cost allowability at 2 CFR 200.403 on a case by case basis if there are compelling reasons for a recipient to use EPA funds to continue to compensate employees who are unable to work on activities that the recipient carries out under EPA financial assistance agreements.  Recipients must, among other things, demonstrate that it’s policies and practices provide for compensating employees who are unable to work on activities that are not Federally funded.  Additionally, recipients must provide financial information establishing that it cannot compensate employees from other sources of funds to perform different work. Recipients should follow the procedures described in the answer to the FQ “How should EPA grant recipients request that EPA provide them administrative relief from a requirement due to COVID-19?” to request authorization by sending an email to the Grant Specialist and Project Officer providing a brief justification.  

Return to Frequent Questions about Grants and Coronavirus (COVID-19).