Sponsored Research Resources and FAQs
COVID-19 Research Related Resources
Last Updated: April 19, 2020
General Guidance
Office of Management and Budget Memorandum M-20-11
Memo on Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus
https://www.cogr.edu/sites/default/files/M-20-11.pdf
Office of Management and Budget Memorandum M-20-17
Memo on Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations
https://www.whitehouse.gov/wp-content/uploads/2020/03/M-20-17.pdf
Office of Management and Budget Memorandum M-20-18
Memo on Managing Federal Contract Performance Issues Associated with the Novel Coronavirus (COVID-19)
https://www.whitehouse.gov/wp-content/uploads/2020/03/M-20-18.pdf
Office of Management and Budget Memorandum M-20-20
Repurposing Existing Federal Financial Assistance Programs and Awards to Support the Emergency Response to the Novel Coronavirus (COVID-19)
https://www.whitehouse.gov/wp-content/uploads/2020/04/M-20-20.pdf
Office of Management and Budget Memorandum M-20-21
Memo on Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19)
https://www.whitehouse.gov/wp-content/uploads/2020/04/Implementation-Guidance-for-Supplemental-Funding-Provided-in-Response.pdf
NIH
Coronavirus Disease 2019 (COVID_19): Information for NIH Applicants and Recipients
Summary of guidance to date from NIH
https://grants.nih.gov/grants/natural_disasters/corona-virus.htm
NIH Late Application Policy Due to Public Health Emergency (UPDATED)
Provides guidance for late applications
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-091.html
Proposal Submission and Award Management Related to COVID-19
Addresses general questions associated with proposal submission and award management. Some guidance on travel, cancelled conferences, etc.
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-083.html
Flexibilities Available to Applicants and Recipients of Federal Financial Assistance
Addresses a range of topics related to Pre-Award Costs; Extension of Post-Award Financial and Other Reporting; Prior Approval Requirement Waivers; Salaries, stipend, etc.
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-086.html
Frequently Asked Questions (FAQs) COVID-19 Flexibilities for Applicants and Recipients (UPDATED)
Offers an array of Frequently Asked Questions (and Answers) in response to inquiries on policies and programs affecting the grants process.
https://grants.nih.gov/faqs#/covid-19.htm?anchor=question55754
Guidance for NIH-funded Clinical Trials and Human Subjects Studies Affected by COVID-19
Addresses specific concerns for NIH funded Clinical Trials and related IRB protocols
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-087.html
COVID-19 Pandemic Response Resources and FAQs for Animal Care and Use Programs
Address specific concerns about NIH Funded Animal Care and Use.
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-088.html
https://olaw.nih.gov/education/educational-resources/webinar-2020-04-08.htm
NSF
Important Notice No. 146 NSF Letter to Community Regarding COVID-19
Confirmation and Updates regarding NSF’s response to COVID-19
https://www.nsf.gov/pubs/issuances/in146.jsp
NSF Implementation of OMB Memorandum M-20-17
Guidance document that outlines the NSF Implementation related to M-20-17
https://www.nsf.gov/bfa/dias/policy/covid19/covid19_nsfombimplementation.pdf
Dear Colleague Letter on the Coronavirus Disease
Announces funding for COVID-19 related research.
https://www.nsf.gov/pubs/2020/nsf20052/nsf20052.pdf
Frequently Asked Questions (FAQs) About the Coronavirus Disease 2019 (COVID-19) for National Science Foundation (NSF) Proposers and Awardees
An extensive set of FAQ associated with proposal submission and award management.
https://www.nsf.gov/pubs/2020/nsf20053/nsf20053.jsp#q4
Dear Colleague Letter from the Directorate for Biological Sciences
Announces NSF BIO’s plans for the COVID-19 Response
See PDF
NSF Implementation of OMB Memorandum M-20-20
Guidance document that outlines the NSF Implementation related to M-20-20
https://www.nsf.gov/bfa/dias/policy/covid19/covid19_nsfomb2020implementation.pdf
NSF COVID-19 Impact on Existing Deadlines
NSF will be extending the deadline date for the solicitations or Dear Colleague Letters (DCLs) as listed on their website. Please check back for updates.
https://www.nsf.gov/bfa/dias/policy/covid19/covid19_deadlines.pdf
DOD
Frequently Asked Questions for DOD Research Proposers and Awardees Impacted by the Novel Coronavirus (COVID-19)
An extensive set of FAQ associated with proposal submission and award management.
https://basicresearch.defense.gov/COVID-19/Frequently-Asked-Questions/
DOE
Accommodating Interruptions from Coronavirus (COVID-19)
Updated information on DOE’s plans for dealing with Covid-19
Accommodating Interruptions to Applicants (PDF)
Department of Energy Letter Addressing Coronavirus (COVID-19)
Dear Colleague letter on Covid-19 from the DOE
DOE COVID-19 letter (PDF)
USAMRAA
United States Army Medical Research Acquisition Activity COVID-19 FAQs
An extensive set of FAQ that talks about general federal guidelines and also those specific to Department of Defense
https://www.usamraa.army.mil/Shared%20Documents/COVID-19%20FAQs%20-%20USAMRAA_CLEAN.pdf
Other
Council on Governmental Relations FAQs on COVID-19’s Impact on Federal Awards – Version 2.2https://www.cogr.edu/sites/default/files/COGR%20FAQs%20on%20COVID-19%20Impact%20on%20Federal%20Awards%20V.2.2.pdf
Council on Governmental Relations Institutional and Agency Responses to COVID-19 and Additional Resources
https://www.cogr.edu/institutional-and-agency-responses-covid-19-and-additional-resources
Office of Management and Budget Memorandum M-20-11
Memo on Administrative Relief for Recipients and Applicants of Fed ral Financial Assistance Directly Impacted by the Novel Coronavirus
https://www.cogr.edu/sites/default/files/M-20-11.pdf
Occupational Safety and Health Administration guide
General guidance for all U.S. workers and employers
https://www.osha.gov/SLTC/covid-19/controlprevention.html
FAQs for Coronavirus Disease 2019 (COVID-19)-Sponsored Award Guidance
Last Updated: May 19, 2020
Please note this is a developing situation and that this guidance may be revised. We encourage you to consult this document regularly as you consider changes to your travel and research plans.
For additional questions, contact Jennifer A. Ponting: ponting@uchicago.edu
Proposals Submission
1. What happens if I am unable to submit my proposal on time due to changes implemented related to COVID-19?
URA remains open and the Pre-Award Team will process and submit applications. The following apply if you are unable to submit your proposal due to lab closure.
NIH issued a notice, NIH Statement on Late Applications Due to COVID-19, on March 10, 2020 to address late submissions. When delays occur because the applicant or recipient organization is officially closed or unable to submit grant applications due to the effects of COVID-19, the NIH will consider accepting applications late, on a case-by-case basis, in accordance with the NIH Grants Policy Statement, Section 2.3.9, under the following circumstances:
- Institutions must submit applications or reports as soon as possible after reopening or resuming operations so that grant applications can be submitted, not to exceed the number of days the institution was officially closed or unable to submit grant applications.
- Institutions must submit a cover letter with the applications with enough detail about the delay so that NIH staff can make a determination whether circumstances justify accepting the application late.
- Institutions need not request advance permission to submit late due to this declared emergency.
NSF (FAQ # 17) also states that researchers or sponsored projects office staff from organizations that have been affected and are unable to meet stated NSF deadlines should contact the cognizant NSF program office to discuss the issue. NSF will consider extensions to the submission deadline on a case-by-case basis (and, in a few cases, on a program-by-program basis), understanding that it may be particularly difficult for individuals impacted to contact NSF.
2. What happens if government employees are furloughed or are unavailable to perform their duties (e.g., they are unavailable to review issue prior approvals or process awards)?
If this happens, we expect that funding agencies will issue guidance. At this point, URA has heard directly from NIH that they are expecting to remain open and available to support our research. We will update this page as we receive additional information.
3. Will agencies consider longer no cost extensions if needed to finish a project after the COVID-19 crisis is over?
NSF FAQ #9 states that all NSF awards are eligible for one-year grantee-approved no-cost extensions and then further extensions as approved by NSF. If you foresee a need for NSF-approved extensions, you should include that information in your annual report and discuss the need ahead of time with the cognizant NSF program officer for your award.
NIH recipients can request funded extensions by working with their division and URA Post-award Administrator to contactthe funding IC (see NIH COVID-19 FAQs).
Researchers should document the actual impact of COVID-19 on the progress of their grants to provide substantiation for any future no cost extension request.
Sponsored Award Management
1. Can we continue to charge effort/salary to a sponsored project during the COVID-19 situation?
Yes. Most agencies and sponsors are deferring to institutional policy regarding compensating personnel during extraordinary and extenuating events. Current University Policy and Guidance allows for personnel to continue to be charged to sponsored projects regardless of whether they are contributing to the progress of a sponsored award.
The PI/Lab/Department should document and retain information on the staff and related compensation that is charged to each award when no contribution is made to the project.
2. How long can salary charges remain on sponsored awards for employees unable to perform the tasks on the awards as a result of the shift to remote work?
The University has extended COVID-19 compensation through the end of the Spring Quarter or June 13th. This policy closely aligns with OMB’s administrative relief, that allows for charges for idle work through June 16th.
Unless both the emergency relief is extended by OMB and the University chooses to extend its Temporary Policy on Pay and Leave Time Related to COVID-19 charges for compensation for those unable to work due to COVID-19 must be moved from the award to a non-sponsored funding source as of June 13, 2020.
3. Can I proceed with planned changes in salary allocations to a new grant even if the individual I am planning to move is not able to work?
No. While it may be allowable to leave salary charges on funding sources in place at the time of the emergency declaration, it is not allowable to move salaries to an award if the individual is not working on that project.
4. How does remote work arrangements during the COVID-19 pandemic impact new requests for summer salary charge to a sponsored award?
Summer pay is not guaranteed compensation. Summer salary can be requested for work being performed remotely that benefits a sponsored project. If work cannot be performed, salary cannot be requested.
5. I am self-isolated, quarantined and/or caring for a sick family member and will not meet the grant submission deadline. May I request an extension?
For NIH grants, NIH addressed this issue in a notice on March 10, 2020, available here (see question 9).
For NSF grants, NSF has already created a COVID-19 website which is here and prior to that NSF issued guidance as part of its FAQs, available here (see question 16).
Please review these notices and contact URA’s Pre-award Team for additional guidance or information about other sponsors.
6. Will agencies consider longer no cost extensions if needed to finish a project after disruption?
The NSF issued FAQs about COVID-19, available here. Question 9 addresses extension requests. Other agencies have not issued specific guidance.
Researchers should document the actual impact of COVID-19 on the progress of their grants to provide substantiation for any future no cost extension request. Agencies have not provided guidance regarding whether they will consider longer no-cost extensions than normal, or multiple no-cost extensions.
7. Will agencies consider deadline extensions for reporting obligations affected by COVID-19? How do we go about managing these?
NIH’s NOT-OD-20-086 provides flexibilities around pre-award costs, extension of reporting deadlines, prior approval waivers, and flexibilities around salary, stipends, travel, and conference costs.
URA has developed a standard communication template to be submitted to URA Post-Award RA should you need to take advantage of any of the flexibilities. The URA Post-Award RA should be notified as soon as possible of any exception that you intend to request with an explanation of the project specific circumstances.
Other funders may be allowing similar flexibilities and such requests can be initiated with URA.
8. If travel restrictions or prohibitions are affecting my research, who should I talk to?
You should initially speak to your division and URA Post-award Administrator and then contact the program officer and grants management contact at the sponsor.
9. Should we continue to pay our subrecipient invoices if they have lab restrictions due to the COVID-19 pandemic?
Yes. Any flexibilities related to the COVID-19 pandemic from our sponsors are flowed down to subrecipients. Invoices from subrecipients reflect costs incurred according to their institutional policies. The costs, therefore, are allowable on the sponsored award.
10. I can’t get to my research site and my research will be severely impacted. Will the sponsor provide incremental funding so that I can successfully complete the aims of the award?
Please contact your URA Post-Award Administrator. He or she can communicate your situation to the program officer at the sponsoring agency. Some agencies will provide supplements to address unexpected events that threaten the original scope of work and objectives. We will continue to post supplemental funding and updates as they become available.
11. I am a researcher who is interested in studying COVID-19. Is funding available to support such research?
Yes. Please visit https://researchcontinuity.uchicago.edu/research-funding/ for up-to-date information.
12. Can Personal Protective Equipment (PPE) and other supply or equipment costs be charged to sponsored awards?
A) Standard PPE
PPE and related equipment and supplies required to be purchased for a sponsored project as a part of standard best lab practice PRIOR to COVID-19 can continue to be direct charged to a grant during or after COVID-19.
B) Additional PPE – Equipment required to resume research
PPE and related equipment and supplies can be charged to sponsored awards if needed to conform with research resumption requirements and such costs are being allocated to all awards benefiting from the activity (e.g., all sponsored projects and all non-sponsored activities with similar needs are required to cover the cost of such items.) For example, if an experiment requires two individuals to stand within 6 feet of each other, any PPE needed to conduct that experiment would be an appropriate charge to the sponsored project during the re-opening phase even if no PPE for that experiment was considered necessary prior to COVID-19. Considerations for allocating these costs should include, the projects the salary/effort of the individuals is being charged to, or an allocation methodology.
On-going maintenance or cleaning costs to remain open during the COVID-19 pandemic should not be charged to sponsored awards.
C) Additional PPE – Beyond standard equipment but not required to resume research
Items not required for resumption, (e.g. PPE acquired for the personal preference of the individuals involved) cannot be purchased on sponsored funds.
Travel Related FAQs for Sponsored Awards
The University has suspended all nonessential international and domestic University travel, effective immediately through April 15. Before considering charging cancellation fees or non-refundable travel expenses to a sponsored award, please attempt to first contact the vendor to request the cancellation fees be waived or travel expenses refunded before they are charged. Procurement Services may be able to assist with Waivers/Refunds and has further information on general University travel policies.
1. I charged airfare to a grant for a conference that I was planning to attend, and the conference was just cancelled. The airline offered a credit for future travel. Can I charge the cost of the airfare and any associated fees to the grant?
It depends. If you plan to travel in the future for the benefit of that grant, then the credit should be tracked to ensure it is used to directly benefit the grant that incurred the cost.
If you plan to use the credit for other travel in support of other research (not related to the grant that funded the airfare), then the charge should be journaled to the appropriate funding source to align the airfare cost with the account supporting the grant that will benefit from that travel. This should be done as soon as possible to avoid Late Cost Transfer requests.
2. What should I consider when booking sponsored travel? What can I do to minimize cancellation costs, if I need to cancel due to COVID-19?
To minimize cancellation costs, we recommend that you:
- Book travel through the University’s preferred vendor Fox World Travel
- Consider lodging that doesn’t require a lodging deposit.
- When planning or attending conferences, consider all costs that may be associated with the cancellation.
- Stay updated on COVID-19 by regularly visiting the University’s COVID-19 website for updated information at https://coronavirusupdates.uchicago.edu/.
3. Can I charge trip insurance to sponsored awards due to unknown future travel restrictions?
No. Trip insurance should not be charged to sponsored awards. URA is monitoring guidance issued by the federal government related to travel. If you need to travel in the coming months for a sponsored project, and you want to purchase trip cancellation insurance, you may reach out to your assigned URA post-award administrator to request prior approval from the sponsor to charge this cost to the grant.
Please note: trip insurance does not cover many situations that force a cancellation; therefore, we would recommend you purchase refundable airline tickets, work with preferred vendors, and consider lodging that does not require a lodging deposit.
4. A student flew out early to visit friends for a couple days before a conference. The conference was being charged to a grant. While visiting, the student learned the conference was cancelled. Is the return flight reimbursable?
The flight is reimbursable with non-sponsored funding. This cost should not be charged to sponsored awards.
IRB Research Related FAQs
If you have an NIH Funded Clinical Trial please see NOT-OD-20-087 which provides Guidance for NIH-funded Clinical Trials and Human Subjects Studies Affected by COVID-19. You may also find the information provide in the “FDA Guidance on Conduct of Clinical Trials of Medical Products during COVID-19 Public Health Emergency” to be helpful.
1. Are the relevant IRB Offices open?
The BSD, SBS and SSA IRB Offices are currently open. IRB staff have the ability to work remotely. We expect minimal disruption to IRB operations.
Posted April 19, 2020
2. I need to modify my existing IRB submission immediately because of COVID-19. What should I do?
Please contact the relevant IRB via the email address below. In the email, list the study number and the reason for the revision. Your email will be routed to the appropriate IRB administrator.
- Biological Sciences Division (BSD) IRB: https://biologicalsciences.uchicago.edu/irb-home
- Social and Behavioral Science IRB: https://sbsirb.uchicago.edu/
- Email: sbs-irb@uchicago.edu
- Social Service Administration (SSA) IRB: https://www.ssa.uchicago.edu/institutional-review-board
- Email: ssairb@uchicago.edu
Posted April 19, 2020
3. Can I still interact with my research participants?
This depends on the nature of your research and where activities occur.
For the Biological Sciences Division: As of March 15, 2020, UCM restricted visitor access which will impact clinical research operations, excluding clinical trials. Please refer to BSD specific communications or contact the Office of Clinical Research for additional information.
For Others: As announced by the Office of the Provost on March 16, 2020, University Researchers who conduct human subjects research involving person-to-person contact that does not have direct health benefits to the subject should suspend such activity immediately. Where possible, develop possible alternatives to in-person study visits such as using remote technology to instead of meeting in person and follow the steps on IRB Modification above.
Ultimately, the Principal Investigator should use reasoned judgment about whether to take measures like adjusting the timing for subject enrollment, suspending enrollment, etc., with the understanding that some such measures may require sponsor notification and/or IRB notification and approval.
Posted April 19, 2020
4. What should I do if I need to modify our study procedures so they occur remotely?
If the Principal Investigator decides to modify study procedures in order to protect participants and/or study staff, e.g., to replace in person visits with remote options for questionnaires, surveys, focus groups, check-ins, screening, consenting, etc., s/he should submit a “study modification” or “amendment” for IRB Approval prior to implementation in AURA IRB. Please note: It may not be necessary to modify your IRB-approved protocol if it does not specify whether interaction will occur in person or remotely.
If it is in the best interest of researchers and participants to eliminate immediate apparent hazards, the Principal Investigator may implement changes without prior IRB approval, but must report such action as in AURA IRB within 5 business days of the modification. Please note that this exception is only for projects that cannot otherwise wait for an amendment to be approved because of immediate hazards to participants; studies that can pause and submit amendment for approval should do so.
Posted April 19, 2020
5. What should I do if I need to submit a change to my research, report new information, or start new research and the IRB office is not in operation?
The human subject protection regulations state that new human subjects research may not start without IRB review and approval. The regulations also state that no changes in already approved research may be initiated without prior approval by the IRB. The only exception is when a change is necessary to eliminate apparent immediate hazards to study subjects. But even in this situation, you will still need to report the event to the appropriate IRB. In an instance where your IRB office is not in operation on campus, all University IRB offices use an electronic submission system, can work remotely, and can hold an IRB meeting virtually. As the COVID-19 situation evolves, we will keep you updated on next steps as it relates to ensuring IRB review for all University researchers but as we mentioned above currently all IRB offices are open and operational.
Posted April 19, 2020
6. Will the IRB continue to review protocols for future work when the University restrictions are lifted for in person protocols?
BSD-IRB: Yes, the BSD-IRB is continuing to review new projects but strongly recommends reaching out to COVID19-IRB@bsd.uchicago.edu for further information and direction.
SBS-IRB: Yes, the SBS- IRB will continue to review new projects that propose in-person activities, but the materials must clearly state their plans to not begin in-person or face-to-face activities until the university announced that it is permissible to do so.
SSA IRB: Yes, the SSA- IRB continues to review new IRB applications (new projects) but cannot approve methodologies or procedures, at this time, that include in-person contact with research participants.
Posted April 19, 2020
Miscellaneous
1. Is there institutional advocacy occurring for federal stimulus package components to include funds to recover lost research productivity?
The University is engaging with our national association partners (COGR/AUU) to advocate and discuss the challenges related to research issues including delays and productivity loss. NIH has confirmed and will continue to provide updates about their willingness to be flexible and provide accommodations during this period. They also confirmed that both NIAID and NIEHS have already received supplemental COVID-19 funds that will be distributed and available. In addition, the Federal Relations Office in Washington DC is tracking the stimulus package that is currently on the Hill. As some of you may remember, the 2009 package did include support of research.
Posted March 16, 2020