Research Continuity Planning for 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.

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.

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. 

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

Yes. Please visit https://researchcontinuity.uchicago.edu/research-funding/ for up-to-date information.

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.

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.

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/.

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.

The flight is reimbursable with non-sponsored funding. This cost should not be charged to sponsored awards.

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

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
  • Email: COVID-19irb@bsd.uchicago.edu or bsdirb@bsd.uchicago.edu
• 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

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

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

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

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

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