Contract and Grant FAQs

Please visit the Research Affairs webpage on COVID-19-related research opportunities.

Conducting any sponsored activities require multiple offices to review and negotiate the terms of the sponsored award and to assist you in obtaining required institutional approvals (e.g., IRB, IBC, etc.). You should immediately contact your assigned Contract and Grant Officer, who will then provide you information on next steps.

NIH will consider administrative supplements to support existing resources that were diverted due to COVID-19, where the faculty member may have donated personal protective equipment, lab equipment, lab supplies, or travel costs to support COVID-patient care, etc. See NIH FAQs.

Please contact your agency program managers as soon as possible, by phone and in writing, to ensure they are fully aware of the challenges and likely costs to your grant for which you will require supplemental funding. If your agency program manager is supportive of a request for supplemental funding, please contact your Contract and Grant Officer for the next steps.

If you overspend on your grant:

• You will have to use your discretionary funds to pay the overage.
• If you run out of discretionary funds, your department will have to pay the remainder.
• If your department runs out of discretionary funds, your division will have to pay the remainder.

In general, yes, provided you remain engaged in your project. Current sponsor prior approval requirements regarding disengagement and effort reductions remain in effect.

Yes. Pursuant to the university’s indirect cost rate agreement with the federal government, sick leave and other paid absences that are permitted under university policy are claimed on federal awards as part of the normal cost of salaries and wages.

NIH provided guidance that allows institutions affected by COVID-19 to continue providing stipend payments to fellows and trainees who may be unable to work as a result of or related to COVID-19. Please work with your Contract and Grant Officer to notify the assigned NIH grants management official, and provide documentation demonstrating the effect of COVID-19, and how long the institution will be affected.

On March 20, 2020, the federal OMB issued a memorandum providing federal agencies with additional flexibilities for grants to allow for COVID-19-related reimbursements, such as allowing administrative leave to be charged against federal grants during the current COVID-19 crisis. As such, this paid administrative leave is an allowable cost could be charged to federal grants and contracts consistent with other employee benefits.

NSF, NIH, and DOD confirmed that they will allow UCSD charge this administrative leave to currently active awards as it is consistent with our policy of paying salaries under unexpected or extraordinary circumstances. UC Office of the President noted on March 24^th that they expect all federal awarding agencies adopt policies and release guidance that are uniform and consistent in providing additional administrative flexibility in light of the COVID-19 pandemic.

Many non-profit and foundation sponsors have issued guidance providing for similar administrative flexibilities as federal agencies.

In the event that a sponsor does not afford such flexibility, these costs should be removed.

For NSF read: https://www.nsf.gov/bfa/dias/policy/covid19/covid19_nsfombimplementation.pdf.

For NIH read: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-086.html.

For DOD read: https://basicresearch.defense.gov/COVID-19/Frequently-Asked-Questions/.

NIH is allowing an individual’s salary to be charged against a grant if said individual is redeployed to provide for clinical care for COVID-19 patients. Please contact your Contract and Grant Officer if you need to divert research personnel to care for COVID-19 patients. See NIH FAQs.

In most cases, grantees should be able to continue work until their period of performance and funding is exhausted. Contact your sponsored project office for further information.

Automated payment systems utilizing Letters of Credit (e.g. PMS, ACM$, ASAP) generally remain active unless the government shuts down due to a lapse in appropriations. However, actions requiring agency action, such as invoice approval, may be delayed if federal staff are unavailable. We expect further guidance will be forthcoming from agencies if it appears that their core functions, such as processing payments, will be unable to be sustained.

If personal protective equipment was required to be purchased for a sponsored project as a part of standard best lab practice prior to COVID-19, it can continue to be direct charged to a grant during or after COVID-19 as well.

NIH indicated that if project-purchased personal protective equipment (or other lab supplies) were donated during the pandemic for clinical or first responder use, then the grant may re-purchase personal protective equipment and charge such costs to the grant. Administrative supplements may be available if re-budgeting is inadequate to replace the donated personal protective equipment.

The majority of other federal agencies require agency-prior approval to donate personal protective equipment; thus, any donated personal protective equipment should either be replaced (using non-sponsored fund sources) or the PI should request agency prior/retroactive approval. If approval is received, replacement personal protective equipment can be charged to said award. Please work with your Contract and Grant Officer on such requests.

Additional personal protective equipment may be charged to grants if needed to conform with research re-opening requirements and such costs are being uniformly charged to the benefiting activity. 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 personal protective equipment needed to conduct that experiment would be an appropriate charge to the sponsored project during the re-opening phase even if no personal protective equipment for that experiment was considered necessary prior to COVID-19.

Additional personal protective equipment not required to conform with research re-opening requirements (e.g., personal protective equipment acquired for the personal preference of the individuals involved) should not be purchased on sponsored funds.

Supplies needed for cleaning should be covered by a non-grant account.

We have been asked by the UC Office of the President to track all COVID-19-related expenses. Please ensure that you keep careful track of these expenses.

You may find more useful information through the Council on Governmental Relations (COGR) webpage "FAQs Regarding COVID-19's Impact on Federal Awards."

These types of expenses are considered administrative costs (indirect costs), and generally are not appropriate as a direct cost unless specifically approved by the sponsor. You may wish to talk with your supervisor about your needs in order to be set up to work from home.

PIs remain responsible for conducting their research in a safe and secure manner. University leadership is providing resources and assistance to aid PIs as they make decisions regarding their research. Accordingly, if project activities are impacted, PIs should contact their immediate supervisor, unit leadership (chair, dean, ORU director), central offices (particularly OR, IRB, IACUC, IBC, OCV, EH&S, etc.), collaborators or sponsors as they feel appropriate.

Please contact your Contract and Grant Officer as they will work with you to submit any necessary notice or prior approval request to the sponsor.  They will also coordinate any necessary reviews by UCSD’s Export Control Office.

Many sponsors allow for one-year, grantee-approved, no-cost extensions at the end of a project’s performance period. If your sponsor does not provide this pre-approval, please contact your unit’s grants administrator to determine how to make a request to the sponsor.

Yes, many sponsors have expressed that they will be flexible with prior approval requirements for administrative changes to a grant. For example, NIH stated on a call that prior approval will not be required for the carryover of an obligated balance. If you have a specific question about a change to your grant, please contact your Contract and Grant Officer.

Please also see OCGA’s At-A-Glace summary of Federal sponsor guidance regarding COVID-19 flexibilities affecting contracts and grant (March 26, 2020)

A contract is where the principal purpose of the instrument is to acquire research services for the direct benefit or use of the other party – they are not as flexible as grants.

Please be proactive in your engagement with your scientific counterparts at the sponsor to help them understand whether any/all work can proceed, and to discuss scope or financial impacts. Please involve your Contract and Grant Officer in any conversations with Contract Officers at the sponsors and formal prior approval requests or no cost extensions. If you are unsure if your project is funded by a grant or contract, please contact your Contract and Grant Officer.

See OCGA’s blink page on Guidance from Sponsors and Research Partners Regarding the Impact of COVID-19 on Research: https://blink.ucsd.edu/sponsor/ocga/covid-19-updates.html.

See NIH Extramural Response to Natural Disasters and Other Emergencies: https://grants.nih.gov/grants/natural_disasters.htm

See NSF Responses to Natural Disasters: https://www.nsf.gov/naturaldisasters/

Most federal agencies do not grant prior approval for late submissions; however, there are existing policies that address extenuating circumstances.  We strongly encourage you to discuss your specific situation with both your agency program officer and your sponsored project contact.

NIH: You may be able to submit a grant proposal after the deadline. Read NIH LATE APPLICATION POLICY Due to Public Health Emergency for United States for 2019 Novel Coronavirus (COVID-19) (NOT-OD-20-082) for details.

NSF: You may be able to submit a grant proposal after the deadline. Read FAQ #16 “Can I receive an extension to the deadline?” for details. NSF has extended the deadline dates for specific funding opportunities. A listing of these extensions is available on the Foundation’s COVID-19 webpage.

DOD: Recommended that program offices provide flexibility with upcoming proposal deadlines to the extent allowable by funding authorities and by the need to have enough time for merit review of submitted proposals.  Please contact the program officer and grants manager for the funding opportunity in question to seek an application deadline extension. Read: Frequently Asked Questions for DOD Research Proposers and Awardees Impacted by the Novel Coronavirus 

DOE: Deadlines for submitting pre-applications, letters of intent, or applications may be extended by no more than fourteen (14) days from the applicable due date. Please contact the Program Manager identified in the FOA or DOE Laboratory Announcement under which the pre-application, letter of intent, or application is being submitted prior to the applicable due date. Read: DOE Memorandum for Applicants and Awardees

NIH will allow recipients that are affected by COVID-19 to delay submission of financial, performance and other reports required by the terms and conditions of the grant award, provided proper notice about the reporting delay is given by the recipient to NIH. NIH will accept these late reports, but will delay issuing any continuing grant awards until the reports are received and accepted.

NSF has automatically extended the due date for submission of all annual project reports due between March 1 and April 30, 2020, by 30 days. These project reports must continue to be submitted via Research.gov. PIs are reminded that NSF cannot make any new award or supplement any existing award, if the PI(s) or any co-PI(s) has an overdue annual project report; therefore, it is vital that annual reports are submitted by the revised due date.

NSF has automatically extended the due date for submission of all final project reports and Project Outcomes Reports due between March 1 and April 30, 2020, by 30 days. These final reports must continue to be submitted via Research.gov. Recipients are reminded that NSF cannot make any new award or supplement any existing award if the PI or any co-PI(s)s has an overdue final report; therefore, it is vital that final reports be submitted by the revised due date.

DOD will allow grantees to delay submission of financial, performance and other reports on currently-active award accounts up to three months beyond the normal due date.  For any other deliverables related to research awards, please contact the DOD grants manager and/or program manager for award specific guidance. 

DOE guidance states that progress reports for grants, cooperative agreements, and interagency awards may be submitted through the PAMS website at https://pamspublic.science.energy.gov as soon as practicable. Note that delays in submitting progress reports may cause unavoidable delays in continuation funding.

Institutions affected by COVID-19 will be allowed to submit post-submission grant application materials to revise information that was submitted in an application as long as the materials are received at least fourteen days before the start of the review meeting. The post-submission grant application materials policy remains in effect.  Only the types of materials allowed under the policy can be accepted. A letter of explanation (maximum of one page) is required. See NIH’s COVID-19 Flexibilities FAQ page.

Please follow the standard eMTA request process which can be found here. Make sure your eMTA request indicates that the transfer is to support COVID-19 related research and contains all relevant information (see pts I & II below).

1. When receiving material: The organization/collaborator providing material to UC San Diego would normally provide the Material Transfer Agreement (MTA). Please be sure to upload that document to the eMTA request. If the provider did not issue an MTA, please note that in the eMTA request.
2. When sending materials: You will need to include additional documents based on the nature of the material you intend to transfer. For bio-materials collected from human donors (i.e, plasma, tissue, sputum, etc.) please include IRB approval notices and related consent documents. UC San Diego will draft the MTA terms and provide it to the organization/collaborator receiving the material.

Contact the MTA Help Desk (mtahelpdesk@ucsd.edu or (858) 246-3682 *please leave a voice message as this VM box is being monitored) to let them know this COVID-19 related transfer is complete and ready for review. Please indicate “COVID-19 related transfer” in the email subject line. If the eMTA request is completed with all relevant information, the MTA Triage Analyst will initiate the steps towards assignment to the appropriate MTA team member.

The OCGA MTA team is doing what they can to help expedite these COVID-19 related transfers, however, providing incorrect or incomplete information may cause delays. If you have any questions or need further guidance, please contact the MTA Help Desk by email: mtahelpdesk@ucsd.edu or by phone: (858) 246-3682.

Please submit a request for an unfunded agreement through this link. Make sure your unfunded agreement request indicates that the agreement is to support COVID-19 related research.

Please email the Ancillary Research Agreement Team at OCGAContractSupport@ucsd.edu once you submit the form to ensure that the agreement request is identified as an urgent request associated with COVID-19.