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. 

NIH guidance states that requesting administrative supplements for additional costs related to COVID-19 exigencies is premature because the full impact of COVID is unknown. Nevertheless, NIH will consider requests for administrative supplements for projects in the following two situations: (1) supplements to existing projects that will allow investigators to immediately address scientific questions of direct relevance to the COVID19 epidemic, and (2) supplements that are needed to address immediate, mission-critical needs over the next 3 months. In determining what is considered “mission-critical” institutions should consider whether the additional funding is required to accomplish the award goals irrespective of the impact of COVID-19.

Please see NIH FAQs for more information.

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 16, 2020, President Napolitano issued an executive order whereby eligible employees would receive a “one-time allotment of up to 128 hours of paid administrative leave,” subject to specific enumerated conditions. OMB issued two memorandums, one on March 19^th (M 20-17) and a second on June 18^th (M 20-26), providing federal agencies with additional flexibilities for grants, including allowing administrative leave to be charged against federal grants during the current COVID-19 crisis. As such, this paid administrative leave allocated by the UC President is an allowable cost that may be charged to federal grants and contracts consistent with other employee benefits.

NSF, NIH, and DOD confirmed that they will allow UC San Diego to 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 to adopt policies in providing additional administrative flexibility in light of the COVID-19 pandemic.

Please note that OMB Memo 20-26 provided additional requirements for the flexibilities afforded by the federal government for the allowability of charging salaries, including exhausting all other funding sources. The consensus of the University of California Contract and Grant Offices is that the aforementioned paid administrative leave is still allowable; however, if an individual has any additional idle time, it should be charged to an unrestricted account. Idle time on research is defined as time that you were unable to work on your research due to disruptions from COVID-19.

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_nsfomb2026implementation.pdf

For NIH read:  https://grants.nih.gov/policy/natural-disasters/corona-virus/nih-omb-memo.htm

You should ask him to estimate, on average, the percent of a regular week that he is able to work. For example, if his estimate is that he is able to complete 80% of his regular week, then at least 20% of his salary should be charged to an unrestricted account.

Through September 30, 2020, NIH is allowing an individual’s salary to be charged against a grant if said individual is redeployed to provide clinical care for COVID-19 patients.

Recipients must exhaust other available funding sources to sustain its workforce and implement necessary steps to save overall operational costs (such as rent renegotiations) during this pandemic period in order to preserve federal funds for grant supported activities. Recipients must retain documentation of their efforts to exhaust other funding sources and reduce overall operational costs.

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.

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.

Please note that the flexibility provided under OMB M 20-20 allowing for the donation of personal protective equipment expired on June 16, 2020.

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 provided flexibilities with prior approval requirements for administrative changes to a grant as allowed under OMB M 20-17. However,  the majority of these flexibilities have expired. 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 (July 12, 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.  OCGA is updating this page regularly with the latest notices from federal agencies. 

No, the F&A rate that was approved at the time your grant or contract was awarded will continue to be applied, even if you and your research staff/trainees are working remotely. The reason the on-campus rate will still be applied is that the research operating costs incurred by your sponsored research activity continue to be incurred even when you are off campus – costs including building leases for your office and research space; permanent infrastructure depreciation; and salaries, health insurance and other benefits for your research administration staff, department finance support, and all the other UCSD employees who help you execute and administer your research without being directly billed to your grant/contract.

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: NIH has announced an updated late policy for the parent institutional training grants which have just a single due date each year. In addition, some NIH ICs have issued late notices for specific funding opportunities, which are posted on the Coronavirus Disease 2019 (COVID-19): Information for NIH Applicants and Recipients of NIH Funding website. For all other Funding Opportunity Announcements NIH is taking a very flexible stance for applications submitted within the standard two-week late policy. Applicants should include a cover letter with an explanation for the late submission.

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: It is recommended that PIs reach out to the DOD contact for the program as each federal agency has different authorities, and there might not be complete uniformity between agencies, components of agencies, or even between programs. 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

We understand that the emergency declaration related to Coronavirus Disease 2019 (COVID-19) will adversely affect the ability of many applicants to generate preliminary data in time for their grant applications. Beginning with due dates on/after May 25, 2020 and until further notice, NIH has issued an exception to our standard policy on post-submission materials and will accept preliminary data as post-submission materials for applications submitted under all activity codes with the following reminders/caveats (NOT-OD-20-123).

• Preliminary data must be submitted 30 days before the study section meeting
• AOR concurrence required
• One page of preliminary data will be accepted for single component applications or for each component of a multi-component application
• Funding opportunity must allow preliminary data (i.e. does not explicitly indicate preliminary data is not allowed)
• Post-submission materials will not be accepted for applications for emergency competitive revisions and urgent competitive revisions which undergo expedited review

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.