On June 18, 2020, the Office of Management and Budget (OMB) issued a new memorandum, M-20-26 Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID–19) due to Loss of Operations, that extends certain flexibilities outlined in previous memorandums as part of the COVID-19 pandemic response. The new memorandum was issued in response to some uncertainty as areas of the country are re-opening and a ramp-up effort is starting for the performance of federally funded projects.
The OMB previously issued three memoranda directing agencies to have certain flexibilities in addressing the shut-down and quarantine issues experienced by federal grantees. The memoranda are identified as M-20-11, M-20-17, and M-20-20.
Memorandum M-20-11, Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19), was issued on March 9, 2020 and allowed agencies some flexibilities for certain requirements under a narrow scope as it was only applicable for awards directly related to the COVID-19 emergency response. These flexibilities are available until July 26, 2020 according to Memorandum M-20-26.
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, was issued on March 19, 2020 and expanded the flexibilities noted in M-20-11 to include all federal grant recipients directly impacted by the loss of operational capacity as well as increased costs related to the COVID-19 crisis. There are 13 flexibilities included in this memorandum and M-20-26 states they expired June 16, 2020 with the exception of extending two of the flexibilities as follows:
- Allowability of salaries and other project activities – Awarding agencies may allow recipients to continue to charge salaries and benefits to active Federal awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Awarding agencies may allow other costs to be charged to Federal awards necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. M-20-26 extends the availability this exception through September 30, 2020 but adds the restriction that 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 the ramp-up effort. Recipients should retain documentation of their efforts to exhaust other funding sources and reduce overall operational costs.
- Extension of Single Audit submission and COVID-19 Emergency Acts Fund Reporting– M-20-17 extended the deadline for submission of the Single Audit report to the Federal Audit Clearinghouse by 6 months for entities with due dates from March 30, 2020 to June 30, 2020. M-20-26 extends this exception through December 31, 2020 and adds a 3-month extension for entities with due dates from July 31, 2020 to September 30, 2020.
Memorandum M-20-20, Repurposing Existing Federal Financial Assistance Programs and Awards to Support the Emergency Response to the Novel Coronavirus (COVID-19), was issued April 9, 2020 and allowed agencies to allow recipients to donate medical equipment (including, but not limited to, personal protective equipment, medical devices, medicines, and other medical supplies) purchased with Federal assistance funds to hospitals, medical centers, and other local entities serving the public for COVID-19 response. Per M-20-26, this exception expired June 16, 2020.
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