OMB Guidance Provides Relief to Federal Award Recipients Amid COVID-19

Nonprofits and higher education institutions continue to be on the front lines of the novel coronavirus (COVID-19) pandemic. As organizations wrangle with ensuring the welfare of their own people and enabling the “new normal” of remote work, they are also contending with how to continue their mission—all while navigating funding uncertainty. 

During the recent weeks, we’ve seen organizations lean into their missions, particularly when they are helping those most affected by the pandemic. While many nonprofits are adapting to the crisis and beginning to plan for the future, many questions remain as this situation continues to evolve.

To help provide some assistance, the Federal Office of Management and Budget (OMB) released a memo on March 19, 2020, providing federal agencies with guidance for managing grants and cooperative agreements during the COVID-19 pandemic. The memo is intended to allow agencies to provide federal award recipients with some flexibility on certain requirements and costs during this challenging time. While the memo aims to provide guidance to federal agencies, federal award recipients should view it as a warranted reprieve from previous requirements.

Specifically, the OMB provides:
  • Flexibility with System for Award Management (SAM) registration (2 CFR § 200.205)
  • Flexibility with application deadlines (2 CFR § 200.202)
  • Waiver for Notice of Funding Opportunities (NOFOs) Publication (2 CFR § 200.203)
  • No-cost extensions on expiring awards (2 CFR § 200.308)
  • Abbreviated non-competitive continuation requests (2 CFR § 200.308)
  • Allowability of salaries and other project activities (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405)
  • Allowability of Costs not Normally Chargeable to Awards (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405)
  • Prior approval requirement waivers (2 CPR § 200.407)
  • Exemption of certain procurement requirements (2 CPR§ 200.319(b), 2 CPR§ 200.321)
  • Extension of financial, performance, and other reporting (2 CPR§ 200.327, 2 CPR§ 200.328)
  • Extension of currently approved indirect cost rates (2 CPR§ 200.414 (c))
  • Extension of closeout (2 CPR§ 200.343)
  • Extension of Single Audit submission (2 CFR § 200.512)
 

How do organizations take advantage of these changes? 

First, be on the look-out for how agencies you work with are leveraging this memo–some individual agencies are quickly adopting this into their own agency-specific guidance. 

Secondly, don’t wait for agencies to act; reach out to federal funders proactively to avail your organizations the flexibilities authorized by the OMB. Given the rapid evolution of the COVID-19 crisis, it is imperative that grantees have direct and frequent communication with their donors, both private and federal, to discuss how the pandemic is impacting their programs and operations. 

Finally, now more than ever, be sure you are communicating the impact of COVID-19 beyond just your donors, but to your beneficiaries as well. It’s important to maintain what we call a nonprofit heart, business mindset in order to ensure your organization can continue to do its critical work.

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