FAQs for COVID-19 - Sponsored Guidance

All FAQs Updated as of 11/24/2020

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 did not adopt flexibilities allowed by OMB M-20-17 for specific award mechanisms, such as contracts or fixed price agreements. Many of these flexibilities expired on June 16th, 2020.

On June 18th OMB issued M-20-26, a memo that extended the ability to continue to charge non-productive time on federal awards with two major limitations: 1) it must be consistent with institutional policies to fund all salaries and, 2) that all other available University funds had been exhausted. Given these imposed limitations, as well as the documentation required, Harvard has chosen not to accept this funding. Therefore, effective June 17th, 2020, only charges for grant related productive work can be charged to federal awards. All charges for idle time MUST be retroactively removed back through June 17th and cannot resume until the employee is able to perform work that benefits the award.

Frequently Asked Questions

1. [New, 6/9/20] Can Personal Protective Equipment (PPE) and other supply or equipment costs be charged to sponsored awards? (See Guidance on Charging PPE to Sponsored Projects on the OVPR website)

A) Standard PPE

PPE and related equipment and supplies required to be purchased for a sponsored project as a part of standard best lab practice PRIOR to COVID-19can continue to be direct charged to a grant during or after COVID-19.

B) Additional PPE – Equipment required to re-open lab

PPE and related equipment and supplies can be charged to sponsored awards if needed to conform with research reopening requirements and such costs are being allocated to all awards benefiting from the activity (e.g., 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 PPE needed to conduct that experiment would be an appropriate charge to the sponsored project during the re-opening phase even if no PPE for that experiment was considered necessary prior to COVID-19. Considerations for allocating these costs should include, the projects the salary/effort of the individuals is being charged to, or an allocation methodology. On-going maintenance or cleaning costs to remain open during the COVID-19 pandemic should not be charged to sponsored awards.

C) Additional PPE – Beyond standard equipment but not required to re-open lab

Items not required for re-opening, (e.g. PPE acquired for the personal preference of the individuals involved) cannot be purchased on sponsored funds.

2) [New, 6/9/20, previously #3] If the progress of my NIH project has been affected by COVID-19, how should I share this information with NIH?

NIH released an updated FAQ (section IV, question 1 of the FAQ), requiring PI’s to report COVID impacts via their RPPR rather than through a letter to their Program Officer. PI’s should only include impact statements on awards that have been impacted due to COVID and address relevant issues of scientific progress. This guidance is specific to NIH and the expectation is that we are still monitoring all awards for COVID impacts as we don’t yet know how other agencies will expect communication on COVID impacts. Please reach out to OSP or your school research administration office with any questions.

3. [New, 6/1/20] If PPE or other medical supplies purchased with sponsored funding was donated to first responders during the COVID-19 pandemic, can we purchase new supplies using sponsored funds? (See Guidance on Charging PPE to Sponsored Projects on the OVPR website)

NIH has indicated that if project-purchased PPE (or other lab supplies) were donated during the pandemic for clinical or first responder use, then the award may re-purchase PPE and charge those costs to the grant. Administrative supplements may be available if re-budgeting is inadequate to replace the donated PPE. Most other agencies require agency-prior approval to donate PPE; thus, any PPE donated should either be replaced (using non-sponsored fund sources) or the PI should request agency prior/retroactive approval. If approval is received, the replacement PPE can be charged to the award. Alternatively, non-sponsored funds can be used to purchase replacement PPE or supplies.

4. [previously #7, updated 6/1/20] 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?

University-related travel, both international and domestic, is prohibited until further notice and should not be planned or scheduled at this time.

Remain updated on the COVID-19 by visiting Harvard University’s COVID-19 website for updated information.

5. [previously #18, updated 6/1/20] Where can I find information about lab re-opening and guidelines?

Please see the Environmental Health and Safety’s COVID-19 resources webpage for information on lab re-opening.

6. [previously #23, [updated 5/22/20] Does NIH have any follow-up regarding the issue of whether graduate students and post-docs will be considered “foreign components” if they are working on grants outside of the U.S. because of travel restrictions resulting from the COVID public health emergency that have prevented them from coming to the U.S.?

NIH stated that the answer to this question is “no” and have posted a FAQ to this effect: NIH FAQ regarding “foreign components.”

7. [Updated 7/17/20] Can we continue to charge researchers and lab personnel to sponsored projects during the COVID-19 crisis?

Yes, if work is being performed on the project. Effective June 17th, 2020, only charges for grant related productive work can be charged to federal awards. All charges for idle time MUST be retroactively removed back through June 17th and cannot resume until the employee is able to perform work that benefits the award.

8. [Updated 7/17/20] How long can salary charges remain on sponsored awards for employees unable to perform the tasks on the awards as a result of the shift to remote work?

Effective June 17th, 2020, only charges for grant related productive work can be charged to federal awards. All charges for idle time must be retroactively removed back through June 17th and cannot resume until the employee is able to perform work that benefits the award.

9. Updated 7/17/20 [Expired] Can I proceed with planned changes in salary allocations to a new grant even if the individual I am planning to move is not able to work?

No. It is not allowable to move salaries to an award if the individual is not working on that project.

Effective June 17th, 2020, only charges for grant related productive work can be charged to federal awards. All charges for idle time must be retroactively removed back through June 17th and cannot resume until the employee is able to perform work that benefits the award.

10. How does remote work arrangements during the COVID-19 pandemic impact new requests for summer/supplemental salary?

Summer/supplemental pay is not guaranteed compensation. Summer/supplemental salary can be requested for work being performed remotely that benefits a sponsored project. If work cannot be performed, salary cannot be requested.

11. Updated 7/17/20 [Expired: M-20-26 did not extend this flexibility] Can travel cancellation expenses and fees caused by the COVID-19 pandemic be charged to sponsored awards?

As of 6/17, with the expiration of OMB memo M-20-17 and release of OMB memo M-20-26, our interpretation is that cancellation expenses and fees are no longer allowed to be charged to federal awards.

12. Updated 7/17/20 [Expired: M-20-26 did not extend this flexibility] When a conference or event is cancelled, what costs are allowable on a sponsored award?

As of 6/17, with the expiration of OMB memo M-20-17 and release of OMB memo M-20-26, our interpretation is that costs associated with cancelled events are no longer an allowable charge on federal awards.

13. 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.

14. I’ve received a credit for airfare, that appears on my Citibank statement, but I have no other expenses incurred, therefore, I cannot submit an expense report in Concur. How do I apply the credit to the account where the expense was charged if I am unable to do this in Concur?

Since you cannot create a report in Concur for credits on a Citibank statement in which there are no expenses, we recommend you request a refund check for the credit by sending an e-mail to fad_corporatecard@harvard.edu with the following:

  • cardholder’s name
  • amount of the credit
  • vendor name
  • transaction date
  • Provide the 33-digit coding for the expense (this is the account string the refund check will be applied to)

Reimbursement and Card Services will request the check from Citi, hide the credit and offsetting transaction (occurs when the check is issued) in Concur, and apply the credit issued via the refund check to the 33-digit coding provided.

For specific questions, please contact Stacey Clifton at stacey_clifton@harvard.edu.

15. [Updated 7/17/20] What if I have a credit for airfare on an award that’s ending in a few months or the credit is due to expire soon? If Harvard’s travel restrictions are still in effect, can the charge for the airfare remain on the sponsored award?

The charge can remain on the originally charged sponsored award if the travel was related to the period of March 19th-June 16th.

16. [Updated 7/17/20] Can name change fees for airfare be charged to a sponsored award?

Airfare credits should be used for the award on which the expense was originally incurred. However, we recognize that in some cases, the original traveler may not be able to use that ticket. In that situation, any of the following are acceptable alternatives:

  • If the travel originally planned can be completed by someone else working on the project, a change name fee can be charged to the sponsored award if the originally planned travel was related to the period of March 19th-June 16th.
  • If the award is still open and the ticket can be used on another award or other school activity, move the ticket cost to the award or other funding source but charge the name change fee to the original award
  • If the award ends and the ticket is not used, leave the charges on the award
  • If the award ends and has incurred the ticket cost and the ticket can be used on another grant or school activity, charge the name change fee to the award or other activity utilizing the ticket

17. 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.

18. 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 sponsorsOSP's COVID-19 guidance summaries for non-federal sponsors, or sponsor websites.

19. What happens if an institution has already submitted an application to NIH, and due to the effects of COVID-19, some of the information needs to be revised?

Institutions affected by COVID-19 will be allowed to submit post-submission grant application materials to revise information that was submitted in an application as long as the materials are received at least fourteen days before the start of the review meeting. The post-submission grant application materials policy remains in effect. Only the types of materials allowed under the policy can be accepted. A letter of explanation (one page max.) is required.

20. 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.

21. 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 sponsorsOSP'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.

22. 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 sponsorsOSP's COVID-19 guidance summaries for non-federal sponsors, or sponsor websites.

23. 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.

24. 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.

25. Should we continue to pay our subrecipient 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.

26. NIH guidance says, “Recipients that are not under Streamlined Non-competing Application Process (SNAP) have the discretion to carry forward unobligated balances on their active grants for immediate efforts to support activities related to or affected by COVID-19 as long as the charges are allowable costs and are within the scope of the original award.” What does NIH mean when they say “affected by” in this statement?

This is interpreted to mean that even though a project may not be related to research specifically on COVID-19, if the COVID-19 pandemic has affected the research from progressing, then recipients not under SNAP may carryforward funds without prior approval. Our interpretation is that all Harvard research transitioned to remote activities may be affected and can fall into this category. Do be aware that carryforward amounts are subject to annual appropriations.

27. 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.

28. 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.

29. [NEW 11/24/20] Should we be using a different F&A rate due to COVID-19?

Questions have arisen relating to charging F&A/indirect costs during the period of lab shutdowns and remote work. Specifically, the following question has been posed several times – is it appropriate to charge the full on-campus F&A rate when all or some portion of the research activities are occurring remotely.

Although Harvard research facilities were temporarily idle, and some remote work continues, Harvard continues to incur the facilities and administrative expenses. Buildings were unoccupied, and some are still partially vacant, but the costs to keep them operational continues. Costs include utilities, depreciation, maintenance, and interest. Additionally, there were significant ramp up costs to allow the labs to reopen with the required social distancing and extra safety precautions. Many incremental costs have continued beyond the reopening, including extra PPE, COVID-19 testing, and increased EH&S costs. In addition to the facility costs, other costs of Harvard’s operational and administrative infrastructure, also supported by F&A, were not and are not currently diminished. There are many other costs recovered through F&A, including grant specific support such as the salaries of grant managers, as well as a portion of shared costs for areas as IT, the offices that run payroll and procurement, security, and the library.

Federal officials have confirmed that they do not expect awardee institutions to change their charges of on-campus F&A rates on federal awards. They explicitly stated that working from home during this period does not require or warrant a shift in indirect cost rates from on-campus to off-campus.

OSP, FAS RAS, and the ORA offices are glad to discuss this issue with any faculty, staff or departments that request further explanation or have further questions.

Additional Questions

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

School contacts: