It depends. The class exception for donations of equipment and supplies provided by the April 9, 2020, OMB Guidance (PDF) expired on June 16, 2020. Therefore, OGD must provide an exception from 2 CFR 200.443(a) regarding the allowability of the costs of donations and the property disposition regulations at 2 CFR 200.313 and 2 CFR 200.314 on a case by case basis to authorize donations of currently unneeded equipment and supplies to hospitals, medical centers, and other local entities serving the public for the COVID-19 response. Additionally, OGD may consider whether the recipient has adequately demonstrated that the group or organization that will receive the donation lacks access to the equipment and supplies due to a lack of funding or otherwise.
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 for donations by sending an email to the Grant Specialist and Project Officer providing a brief justification. If the recipient is requesting supplemental funding as well, the email should indicate the amount of additional funding requested. Note that recipients who make equipment and supplies donations prior to receiving EPA approval do so at their own risk. Also, there is no guarantee that EPA will have the resources to provide supplemental funding, so recipients may need to absorb the costs for the donated equipment and supplies with currently approved EPA funds and request an adjustment to their scope of work if their capacity to meet deliverable requirements is impacted.