FAQs for COVID-19 - Sponsored Guidance

All FAQs Updated as of 3/31/2020

See the “COVID-19 Research-Related Information and Websites” page.

Transactions that relate to COVID-19 specific policies should be carefully and fully documented. All supporting justifications must be retained according to the University record retention policies.

Communications with federal awarding agencies should be coordinated with ORA, OSP or the school’s central research office.

Note on Applicability

These FAQs are for federal and non-federal grants. Some federal agencies are not adopting flexibilities allowed by OMB M-20-17 for specific award mechanisms, such as contracts or fixed price agreements. Please see the sponsor summary guidance on the OSP home page for agency-specific guidance.

The type of award mechanism is listed at the top of the GMAS Segment Home Page under funding instrument.

Compensation Related Questions

1. Can we continue to charge researchers and lab personnel to sponsored projects during the COVID-19 crisis?

Yes. Most agencies and sponsors defer to institutional policy regarding compensating personnel during extraordinary and extenuating events. Current Harvard Policy and Guidance allows for personnel to continue to be charged to sponsored projects regardless of whether they are contributing to the progress of a sponsored award.

Units must keep track of who is working and who is not working, including stipendees, while being paid on a sponsored award. Contact your central office for additional guidance.

2. How long will pay and benefits (if applicable) be guaranteed for eligible Harvard-paid non-faculty academic appointees?

Until May 28 (Harvard’s Commencement day), except for those who were scheduled to terminate, or whose appointments end, sooner. A paid excused absence may be used to ensure pay continuity if work is unable to be performed remotely, up to the regular or standard workweek for the position. The excused absence option will end on the day of a previously scheduled termination or other appointment end date if it is earlier than May 28.

3. Does the guarantee of salary until May 28, 2020 cover Harvard paid research assistants, postdocs, fellows, PhD students and research associates?

Yes, all research scholars, including, but not limited to fellows, postdoctoral fellows, research fellows, PhD students, and research associates (referred to as non-faculty academic appointees), who receive payments from Harvard, whether stipend or salary, also are included. Hospital-paid fellows, postdocs, research associates fall under the policies of their hospitals.

Travel Related Questions

4. Can travel cancellation expenses and fees caused by the COVID-19 pandemic be charged to sponsored awards?

Yes. Under the OMB notices for Managing Flexibility due to COVID-19, agencies have relaxed restrictions for charging cancellation expenses and fees to awards provided the practice is in alignment with University policy and reasonableness.

Some sponsored agencies have not specifically addressed cancellation expenses. At the current time, we recommend that all reasonable fees be charged to awards and documented. If agencies issue alternative guidance, these expenses will need to be removed.

Units must retain documentation relating to the cancellation costs charged to a grant in accordance with record retention requirements.

5. When a conference or event is cancelled, what costs are allowable on a sponsored award?

The first recommended step is to contact the hotel or event venue and see what flexibility they will provide and what the penalties are for canceling or postponement.

In general, conference and event cancellation fees and associated costs may be charged to the sponsored award. If the cancellation of this conference represents a change in the scope of work, please partner with your central office.

If you need assistance in working with the hotel, reach out to your local school contact responsible for procurement and vendor agreements.

Units must retain documentation relating to the cancellation costs charged to a grant in accordance with record retention requirements.

6. I need to purchase airfare for future travel. Can I purchase refundable airfare and charge it to a grant? What should I consider when booking future sponsored travel?

Yes. Refundable airfare purchased during the COVID-19 pandemic may be charged to a grant.

In an effort to minimize cancellation costs, we recommend you:

  • Book travel through Harvard’s preferred vendors.
  • Purchase refundable airfare.
  • Consider lodging that doesn’t require a lodging deposit.
  • When planning or attending conferences consider all costs that may be associated with the cancellation.
  • Remain updated on the COVID-19 by visiting Harvard University’s COVID-19 website for updated information.

7. Can trip insurance be charged to sponsored awards during this time due to unknown future travel restrictions?

No. Trip insurance should not be charged to sponsored awards. Furthermore, trip insurance doesn’t cover many situations for cancelling; therefore, the Travel Office recommends you purchase refundable airline tickets, work with preferred vendors, and consider lodging that doesn’t require a lodging deposit.

Proposal Submission Questions

8. A PI is self-isolated, quarantined and/or caring for a sick family member and will not meet the grant submission deadline. May I request an extension?

It depends on the agency. Both NSF and NIH have issued guidance that allows for submission extensions. For other agencies, please refer to specific programs on agency websites.

9. Will agencies consider longer no cost extensions if needed to finish a project after the COVID-19 pandemic is over?

Many agencies have relaxed restrictions regarding a second, one-year no cost extension. Please refer to OSP’s COVID-19 guidance summaries for federal sponsors, OSP's COVID-19 guidance summaries for non-federal sponsors, or sponsor websites.

Data Security Question

10. If a student or researcher needs to access and/or analyze a data set from home in order to keep working on a project, how do we address privacy requirements if the data set contains sensitive or private information?

As the University prepares to support remote operations, we anticipate that research teams may need to rethink how they access and analyze research data sets. Successful remote research operations during implementation of COVID-19 precautions requires maintaining compliance with required controls:

Our research compliance teams will expedite reviews to the extent possible to support continuity.

For other considerations related to working remotely, we recommend you refer to Harvard University Information Technology’s website on working remotely for guidance.

Research Continuity Questions

11. COVID-19 lab or travel restrictions are affecting my research, what actions should I take?

In general, any impact to your research due to restrictions must be documented. Please refer to OSP’s COVID-19 guidance summaries for federal sponsors, OSP's COVID-19 guidance summaries for non-federal sponsors, or sponsor websites. For additional information or specific questions, please contact OSP or ORA.

Units must keep track of who is working and who is not working, including stipendees, while being paid on a sponsored award. Contact your central office for additional guidance.

12. Due to the COVID-19 pandemic, I cannot complete my grant objectives without additional funding. Have any sponsors addressed this issue?

Sponsor guidance varies on availability of future funding. Researchers must document the actual impact of COVID-19 on the progress of their grants to provide substantiation for sponsor communication coordinated through ORA, OSP, or the central office. Please refer to OSP’s COVID-19 guidance summaries for federal sponsors, OSP's COVID-19 guidance summaries for non-federal sponsors, or sponsor websites.

13. Is there a template for laboratory research contingency planning?

Please see the Environmental Health and Safety guidelines.

14. I have questions about Human Subjects Research. Is there any guidance?

Yes, There are two websites with information, see either the Harvard’s Committee on the Use of Human Subjects website or the LMA IRB website.

15. What happens if government employees get furloughed or are unavailable to perform their duties (e.g., issue prior approvals or process awards)?

If this happens, we expect that funding agencies will issue guidance. Harvard’s guidance and FAQs will be updated as additional information is received.

16. Should we continue to pay our subreceipient invoices if they have lab restrictions due to the COVID-19 pandemic?

Yes. Any flexibilities related to the COVID-19 pandemic from our sponsors are flowed down to subrecipients. Invoices from subrecipients reflect costs incurred according to their institutional policies. The costs, therefore, are allowable on the sponsored award.

Financial Reporting and Invoicing Questions

17. Will OSP continue to submit invoices and financial reports?

OSP Research Finance is planning to continue to process and submit all invoices and financial reports. Departments/Local Level Managing Units will continue to be contacted by OSP as part of the normal processes associated with these submissions.

18. What should a Department/Local Level Managing Unit do if they anticipate that an invoice or financial report will need to be submitted late, as a result of COVID-19 related circumstances?

The coordination of requests for late invoices and late financial reports can continue to be routed to the OSP Financial Analyst portfolio owner. The OSP Financial Analyst should be notified as soon as possible of any invoices or financial reports that may need to be submitted late. The Department/Local Level Managing Unit must provide the OSP Financial Analyst with an explanation of the circumstances so that OSP can coordinate a communication to the sponsor to request an extension of the due date, if necessary. The duration of the extension request will vary by project, depending on the circumstances.

Additional Questions

For questions, please reach out to your school contact listed below or Christyne Anderson.

School contacts: