OMB Issues Memo Authorizing Awarding Agencies to Provide Flexibility and Administrative Relief to Grant Recipients due to COVID-19
On March 19th, 2020, the U.S. Office of Management and Budget (OMB) issued memorandum M-20-17, Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations.
OMB authorized federal awarding agencies the ability to provide the following to recipients and subrecipients:
- Extension of Single Audit submission:
Awarding agencies have been instructed by OMB to allow recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of 3/19/2020 to delay the completion and submission of the Single Audit reporting package to six months beyond the normal due date. This applies to recipients and subrecipients that have fiscal year-ends through June 30, 2020. Recipients and subrecipients are not required to seek approval for the extension, but need to maintain documentation for the reason that filing was delayed.
- Flexibility with SAM registration
- Flexibility with application deadlines
- Waiver for Notice of Funding Opportunities (NOFOs) Publication
- No-cost extensions on expiring awards
- Abbreviated non-competitive continuation requests
- Allowability of salaries and other project activities
- Allowability of Costs not Normally Charged to Awards
- Prior approval requirement waivers
- Exemption of certain procurement requirements
- Extension of financial, performance, and other reporting
- Extension of currently approved indirect cost rates
- Extension of closeout
It is important to note that the memo issued by the OMB was not an order requiring federal awarding agencies to offer the provisions noted above. Rather, the memo is an authorization that allows awarding agencies to make these provisions if deemed necessary. Therefore, each nonprofit should check with their respective awarding agencies about what provisions will be granted. Please also refer to the full memo issued by the OMB on Thursday, March 19th.
With the continuing development of the COVID-19 situation, the Jones & Roth Nonprofit Team is actively monitoring official information released from governing agencies that could impact our nonprofit clients and community. As information becomes available, we will continue to post on the Jones & Roth website.