NSF’s FAQ on M-20-26 Adds Clarity to Agency’s Response

Jerry Ashworth
July 21, 2020 at 13:33:51 ET
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“Let me be perfectly clear…”

That seems to be the message that the National Science Foundation (NSF) wants to get across to its award applicants and recipients affected by the COVID-19 pandemic. NSF sent out a “Dear Colleagues” email today discussing the agency’s response to Office of Management and Budget (OMB) Memorandum M-20-26, Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations, noting that NSF issued agency guidance on M-20-26 to its grantees last month.

In the email, NSF stresses that it “remains committed to working with the administration, other federal agencies and the research community to effectively respond to the COVID-19 national emergency.” It further explains that M-20-26 extends two of the short-term administrative flexibilities from specific uniform guidance requirements originally addressed in the now-rescinded OMB M-20-17. These extensions pertain to the allowability of salaries and other project activities, and single audit submissions. “In order to support charges against NSF awards, recipients are reminded of their responsibility to maintain appropriate records and documentation to support the charges in accordance with institutional policies and procedures,” the email adds.

Now, along with the NSF's June guidance on M-20-26, the agency on Monday also released FAQs relating to NSF’s implementation of M-20-26 for NSF proposers and awardees and for NSF major facility cooperative agreement recipients. This FAQ explains that all prior sets of FAQs related to OMB COVID-19-related memoranda are now rescinded.

The FAQ includes seven questions in all, including one that asks the following: “NSF’s latest COVID-19 flexibility guidance ... requires recipients 'to exhaust other available funding sources to sustain its workforce and implement necessary steps to save overall operational costs (i.e., rent renegotiations, travel, training, utilities, major purchases, etc.) during this pandemic period in order to preserve federal funds for the ramp-up effort.' Who is responsible for determining whether other sources of funding are available, and what steps can/should be taken to save costs?” In response, NSF said that its recipients are responsible for making determinations on the availability of other funding sources, as they are for efforts to potentially reduce costs. If the recipient determines that other funding sources are not available to sustain its workforce, the NSF award may be charged in accordance with OMB M-20-26.

All NSF applicants and recipients are strongly encouraged to read the agency’s guidance to ensure they are complying with agency requirements.

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