Guidance on Sponsored Projects Salary
March 28, 2020
Given the current issues surrounding COVID-19, I am writing to provide a brief update on charging of salaries/fringe benefits to grants and contracts.
The University remains operational, and consequently for all grants/contracts in which project-related activities continue without disruption, all applicable salaries/fringe benefits should continue to be charged accordingly.
If you are the principal investigator of a grant/contract and you anticipate that your project deliverables will be delayed by offsite work or staff disruptions, please contact your program officer or technical point of contact immediately to let them know of your work plan adjustments, and copy the Office of Research and Sponsored Programs firstname.lastname@example.org on the communication. The appropriate ORSP Sponsored Programs Manager will be made aware of the notice. Once the sponsor approves the revised work/effort plan, you may then charge accordingly.
Currently, there remains uncertainty related to what federal agencies will be allowing in regard to charging of salaries/fringe benefits to sponsored programs for which a disruption causes effort to be curtailed. The Office of Management and Budget has released OMB Memo M-20-11 (Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus) and OMB Memo 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) with the intention of providing flexibility to federal agencies in their application of 2 CFR 200, the regulations governing allowable costs. Note that the OMB memos are not direct guidance to recipients of federal financial assistance, and agencies have latitude in how they choose to act on the OMB communication.
As guidance will continue to evolve, especially from specific federal agencies, please refer to the Research Division Information and Resources for COVID-19 (Coronovirus) or contact the ORSP Service Center for information about those agencies that have issued specific guidance at this time.
For salary charges to non-federal sponsors, please follow the same guidance related to direct communication with the sponsor if any alternative work plans are being proposed or sponsored activity is being disrupted.
For grants/contracts in which project-related activities are disrupted and there is not written approval from sponsors for alternative work/effort plans or agency specific guidance in accordance with OMB, units should take one of the following actions:
- Charge efforts/graduate support to an unrestricted funding source for the period of disruption
- Require the employee to utilize paid time off in accordance with University policies, and consistent with normal charging practices
- Contact HR for employee layoff in accordance with University policy and employee offer letters
Thank you for your help in ensuring that we remain compliant with sponsor regulations during this difficult period. For additional guidance or assistance, please contact the ORSP Service Center at email@example.com or call 740-597-6777.
Vice President for Research and Creative Activity
Dean of the Graduate College