COVID-19: Continued Expenses on Grants
Posted on March 26, 2020. Note that some information or advice may have changed since posting.
Dear Notre Dame Research Community,
Notre Dame Research has been carefully monitoring sponsor and University guidance as it relates to the continued allowability of payroll charges to external sponsored program funds (grants, contracts, cooperative agreements, etc.) referred to hereafter as “grants” during the COVID-19 outbreak.
In determining whether pay and benefits for research personnel is allowable on grants, the following guidance applies:
- If research personnel are continuing to generate effort in support of the grant, they can continue to be paid from the grant.
- If research personnel are unable to generate effort in support of the grant, whether they continue to be paid or not by the grant depends upon the University’s position on paying employees from all funds during extraordinary times. (OMB 20-17)
The current guidance regarding paying university personnel can be found in Shannon Cullinan’s letter sent on 3/24/20.
We [Notre Dame] will continue, at this time, to provide pay and benefits to all full-time and benefits-eligible part-time regular employees at their current base rate of pay or normally-scheduled work hours. Pay and benefits will continue for regular employees, including those for whom there is a temporary lack of work, those who are self-quarantined in keeping with public health and University requirements and those who are working from home due to caregiving obligations that have arisen as a result of this health emergency (e.g. widespread school closings).
Please know that this current guidance could change.
There is significant discussion ongoing within federal agencies about whether supplemental funding will be available for projects that expend grant amounts to pay employees during the temporary suspension of research work. Some sponsors have advised that grant recipients should not expect supplemental funding to be available if the temporary suspension of research causes a shortage of funds needed to complete the project. Principal investigators/project directors who expect the suspension of research during this crisis will cause such a shortfall should contact their program officer to discuss the situation.
Individual research sponsors may issue guidance that supersedes the general guidance above e.g. issue a stop-work order, termination notice, or takes a position contrary to the principles in the OMB guidance. In such cases, research personnel may not be able to be paid from those specific grant funds. If you receive any communications from the sponsor that you believe affects our ability to continue incurring grant-related expenses (personnel or other), please contact NDR at email@example.com or (574) 631-7432 or your post-award grants program manager for evaluation prior to taking action.