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Frequent Questions about Grants and Coronavirus (COVID-19)

In response to the COVID-19 crisis, the Office of Management and Budget (OMB) issued three memoranda providing class exceptions allowing Federal awarding agencies to grant various administrative, financial and audit requirement flexibilities to their applicants and recipients.OMB Memorandum M-20-11 (March 9, 2020 OMB Guidance) (PDF) was narrow in scope and only applied where the Federal agency determined that the purpose of their awards was to support continued research and services necessary to carry out the emergency response related to COVID-19 and did not directly apply to EPA awards. The other two memoranda, OMB Memoranda M-20-17 (March 19, 2020 OMB Guidance) (PDF) and M-20-20 (April 9, 2020 OMB Guidance) (PDF), were applicable to EPA awards. Accordingly, the Office of Grants and Debarment (OGD) developed these FQs to supplement the March 19, 2020 OMB Guidance and April 9, 2020 OMB Guidance and to provide information to applicants for, and recipients of, EPA grants and cooperative agreements relating to the impacts of COVID-19.

The flexibilities provided in the OMB memoranda were time limited. As such, on June 18, 2020, OMB issued Memorandum M-20-26 (June 18, 2020 OMB Guidance) (PDF) which provided notification that most of the flexibilities in the March 19, 2020 OMB Guidance and April 9, 2020 OMB Guidance expired as scheduled on June 16, 2020. However, recognizing the uncertainty of the re-opening phase and the speed of the ramp-up effort, the June 18, 2020 OMB Guidance provides an extension of the following two flexibilities: Item 1, Allowability of salaries and other project activities (item 6 in the March 19, 2020 OMB Guidance) through September 30, 2020; and Item 2, Extension of Single Audit submission (item 13 in the March 19, 2020 OMB Guidance) through December 31, 2020. In addition, OMB added restrictions to the flexibilities allowed in item 1, Allowability of salaries and other project activities.

Now that the March 19, 2020 OMB Guidance and April 9, 2020 OMB Guidance are partially rescinded, OGD has updated the FQs to reflect the rescission and the changes described in the June 18, 2020 OMB Guidance.

Note: For the purposes of these FQs, the term “grant” also includes cooperative agreements.

View all frequent questions related to grants and cooperative agreements and Coronavirus (COVID-19) below.

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

On this page:

Grant procedures
Allowable costs
Disruption of operations
Procurements
Extensions
Grant competitions
Suspension and debarment

Grant Procedures

Will EPA grant operations be impacted by the telework enacted in response to the COVID-19?

How should EPA grant recipients request that EPA provide them administrative relief from a requirement due to COVID-19?

Can the Office of Grants and Debarment (OGD) provide exceptions on a case by case basis if a recipient believes a regulatory exception is necessary due to the impacts of COVID-19?

Are flexibilities that EPA approved prior to OMB rescinding M-20-17 or M-20-20 withdrawn?

What documentation does EPA require for resumption of non-competitive awards?

May EPA waive prior approval requirements specified at 2 CFR 200.407 if a waiver is necessary to address COVID-19 related concerns?

Is EPA providing any flexibility with respect to submission of assistance agreement forms/documents that traditionally have required wet ink signatures?

Allowable Costs

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?

If a recipient has received reimbursement for payroll costs under the Paycheck Protection Program (PPP) loans or any other Federal CARES Act programs can those same costs be charged to EPA grants?

If an EPA grant recipient permits their employees administrative leave to comply with social distancing guidance from public officials, are the costs allowable?

Due to the increased demands for assistance in processing unemployment claims, testing for COVID-19, and similar responses to the public health emergency, state, tribal or local governments may seek to re-assign employees working on EPA-funded grants to those projects. Can these recipients continue to charge the costs for compensating the employees to their EPA-funded grants when the employees are performing work unrelated to the EPA grants?

If an EPA grant recipient is forced to lay off employees due to COVID-19 related project terminations, are the costs for severance packages allowable?

If an EPA grant recipient incurs unanticipated costs in resuming performance of an EPA grant after the impact of the COVID-19 public health emergency diminishes, are those costs allowable?

Are cancellation fees for travel or facility rental allowable?

Are cancellation fees for program participant travel allowable?

How would a program participant or recipient employee recoup incurred expenses associated with cancellation if the participant or employee must cancel travel to a meeting or other event either because the event was cancelled, flights were cancelled, or the participant or employee is affected by COVID-19?

Does EPA require recipients to cancel events due to the COVID-19 public health emergency?

Can recipients donate personal protective equipment and supplies, medical devices, medical supplies, and medicines (equipment and supplies) purchased with EPA funds to carry out the EPA grant to assist in the response to the COVID-19 situation?

Are recipient costs associated with 3D printing of Personal Protective Equipment and Supplies (PPES) for donations allowable?

Are unanticipated costs associated with recipient employees teleworking due to COVID-19 social distancing requirements and/or state-local stay at home orders allowable?

Disruption of Operations

Will EPA modify workplans, adjust budgets, and extend project periods of grants if necessary?

Will EPA provide a waiver to the performance period limitations in section 10 of Grants Policy Issuance 11-01 (GPI 11-01), Managing Unliquidated Obligations and Ensuring Progress under EPA Assistance Agreements, for assistance agreements impacted by COVID-19?

If an EPA grant recipient is carrying out a project that will not be completed due to delays in performance what will EPA do?

How will the Agency handle partial terminations/deobligation of funds for projects or portions of projects that cannot be rescheduled?

If a stay at home, shelter in place, or similar order is issued on a state/local/other level that affects the activities performed under a grant (e.g., the order prohibits travel required to perform monitoring or inspection activities), does that prohibit those activities from being performed under the EPA grant?

Will there be any ability to reprogram or redirect federal funds or change the nature of the activities to be performed under a grant based on emergency needs or inability to conduct certain tasks?

Are there legal limits on the amount of time EPA can extend the length of periods of performance of a grant if we cannot perform it within the original period of performance?

As a general matter, how can states avoid losing funds already received for projects that might be delayed?

What about grants to local governments, non-profits and institutions of higher education-how are they funded?

Will there be flexibility regarding inspection requirements under EPA grants to states, tribes or local governments such as those relating to RCRA large quantity generators, 3-year periodic inspection of USTs, and similar inspection requirements incorporated into the terms of EPA grants?

Do regulatory exceptions, waivers and other forms of COVID-19 related relief for EPA grants to pass-through entities (also known as “prime recipients”) extend to their subrecipients?

Can EPA waive “match” or cost share requirements if a recipient is unable to meet the requirement due to budget shortfalls as a result of COVID-19?

Are recipients allowed to use third-party virtual platforms to perform work under EPA assistance agreements?

Procurements

If an EPA grant recipient legitimately needs the immediate support of a contractor to respond to a COVID-19 situation by carrying out activities within the scope of the grant, can it hire the contractor noncompetitively and without EPA approval?

Can EPA waive any other provisions of the Procurement Standards in 2 CFR Part 200, if necessary, to respond to COVID-19?

Extensions

Will EPA extend the dates for financial and performance reporting if a recipient impacted by COVID-19 is unable to comply with existing requirements?

If a recipient is unable to obtain a current indirect cost rate from its cognizant agency due to COVID-19 related disruptions will EPA allow the recipient to continue to use an expired rate?

Will EPA extend the due dates for reports required under 2 CFR 200.343 to close out grants if the recipient cannot provide the information due to COVID-19 related disruptions?

May EPA recipients and subrecipients with EPA as their cognizant or oversight agency delay filing of their Single Audits with the Federal Audit Clearinghouse due to disruptions caused by the COVID-19 public health emergency?

Will EPA extend the dates for Quality Assurance (QA) documents if a recipient impacted by COVID-19 is unable to comply with existing requirements?

Grant Competitions

Can recipients change the activities in the scope of work for competitive grants?

What is EPA doing to accommodate challenges applicants experience in preparing applications due to COVID-19?

What flexibilities are available for applicants that have difficulty registering for SAM.gov and cannot submit applications to EPA through Grants.gov?

Can applicants submit their applications outside of Grants.gov due to the challenges associated with COVID-19?

How will issues or delays recipients are experiencing with performance issues under their grants affect how they are evaluated on past performance evaluation criteria under future competitions?

Suspension and Debarment

Is the Agency still issuing notices of suspension, notices of proposed debarment, or taking other suspension and debarment (S&D) actions?

Will the Agency still issue suspension and debarment (S&D) decisions upon completion of contest proceedings?

How may respondents of a suspension and debarment (S&D) notice contest a notice of suspension, notice of proposed debarment, or show-cause notice?

Will exclusion records on the System for Award Management (SAM.gov) be maintained and updated during COVID-19 operations?