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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?

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 must provide an exception from 2 CFR 200.403(b) on a case by case basis to allow recipients to charge these unanticipated costs to their EPA grant. 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.

There is no guarantee that EPA will have the resources to provide supplemental funding, so recipient recipients may need to absorb these costs with currently approved EPA funds and request an adjustment to their scope of work if their capacity to meet deliverable requirements is impacted.

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