Sneak Preview: Agencies Begin Implementing M-20-17 Exceptions

(The following was excerpted from a recent article in the Federal Grants Management Handbook.) Federal awarding agencies are implementing grant program flexibilities allowed under Office of Management and Budget (OMB) Memorandum M-20-17, with some agencies now making the documents outlining the flexibilities publicly available. Agencies note that recipients should review how these temporary flexibilities may affect their awards’ terms and conditions, and ensure that they maintain appropriate records and documentation to support costs and other actions made while these exceptions are in effect.

On March 19, the agency released OMB 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, which stated that federal agencies may offer flexibilities to recipients who have experienced a loss of operational costs due to COVID-19 disruptions. The exceptions under M-20-17 are for 90 days, and OMB will reassess them by June 19.

M-20-17 enabled agencies to provide exceptions related to the following 13 areas: (1) SAM.gov registration; (2) application deadlines; (3) publishing notices of funding opportunities; (4) no-cost extensions on expiring awards; (5) abbreviated noncompetitive continuation requests; (6) allowability of salaries and other project activities; (7) allowability of costs not normally chargeable to awards; (8) prior approval requirement waivers; (9) exemptions of certain procurement requirements; (10) extensions of financial, performance and other reporting; (11) extensions of currently approved indirect cost rates; (12) extensions of closeout dates; and (13) extensions of single audit submission dates. Not all agencies are expected to implement these provisions in a similar manner.

Among the federal agencies that have implemented M-20-12 provisions are the National Institutes of Food and Agriculture, National Science Foundation, Federal Emergency Management Agency and the Department of Energy.

(The full version of this story has now been made available to all for a limited time here.)

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