COVID-19 Updates for BU Researchers

Q: Will NIH accept late progress reports and financial reports where delays are due to the effects of COVID-19?

NIH issued Guide Notice NOT -OD – 20-086 on March 12: If you are unable to complete and submit a financial and RPPR by the scheduled due date, due to the effects of COVID-19, please contact your SP RA for late progress reports and/or PAFO RA or PAFO Manager for late financial reports, who will contact the assigned grants management and/or program official to let them know the reports will be late.

Note in NIH Guide Notice NOT-OD-20-083, the following guidance has been issued on progress reports (subject to change and institutions are encouraged to check for any updates directly from NIH as they become available): Per NIH Grants Policy Statement sections 8.4.1 and 8.6, as well as the terms and conditions outlined in Notice of Award, NIH requires that recipients periodically submit financial and progress reports. NIH understands that some reporting delays due to the impact of coronavirus may be unavoidable. Therefore, if recipients are unable to complete and submit a progress report ((Research Performance Progress Reports (RPPR)), Financial reports (Federal Financial Report expenditure data), and/or invention report by the scheduled due date, they should promptly contact the assigned grants management and/or program official. Although NIH will accept these late reports, grant awards will be delayed until the required reports are submitted and accepted by NIH.  

Q: Late applications and solicitations where coronavirus (COVID-19) will adversely affect some applicants' and recipients' ability to submit applications in a timely manner.

NIH: When delays occur because the applicant or recipient organization is officially closed or unable to submit grant applications due to the effects of COVID-19, the NIH will consider accepting applications late, on a case-by-case basis, in accordance with the NIH Grants Policy Statement, Section 2.3.9, under the following circumstances:

Institutions must submit applications or reports as soon as possible after reopening or resuming operations so that grant applications can be submitted, not to exceed the number of days the institution was officially closed or unable to submit grant applications.

Institutions must submit a cover letter with the applications with enough detail about the delay so that NIH staff can make a determination whether circumstances justify accepting the application late.

Institutions need not request advance permission to submit late due to this declared emergency.

NIH will be issuing additional guidance related to this public health emergency in the near future.

DOJ: Solicitations with application due dates between March 16th and March 31st will have a 2-week extension for submission.  OJP program offices are in the process of updating those due dates now. OJP will continue to monitor the situation and determine if additional adjustments to closing dates will be needed. Grants.gov and OJP’s Grants Management System remain open to continue to accept applications.

CDMRP ALSRP, ARP and OCRP: Due to impacts of COVID-19, the Amyotrophic Lateral Sclerosis Research Program (ALSRP), Autism Research Program (ARP), and Ovarian Cancer Research Program (OCRP) have extended the pre-application submission deadline. The extension is for all applicants.

Requests for further extensions to the new pre-application submission deadlines will not be accepted.  The FY20 ALSRP released funding opportunities on January 17, 2020. The FY20 ARP and FY20 OCRP released funding opportunities on February 27, 2020.

Please consult the modified Program Announcements available on Grants.gov and contact the CDMRP Helpdesk with any questions (help@ebrap.org)

STScI, NASA, ESA, and CSA have decided to delay the proposal deadline for JWST Cycle 1 GO proposals to no earlier than May 27^th, 2020. We are continuing to monitor the situation and will provide an update on the schedule on April 15^th, 2020.

Please contact the jwst helpdesk if you have any questions.

Q: Where a research project has a strict timeline, we are concerned about a possible failure to perform within the agreed-upon statement of work. This failure may be due to a slow down or gap in activities, particularly where staff may need to work from home.

Clearly, this is an extraordinary situation. If the scope of work demands a precise schedule in order to make an experiment viable, then the investigator should recognize and document instances where that schedule was unable to be met and the data resulting from that experiment may not be able to be used (or can only be used with certain cautions). If it is not the case that such precision is required for scientific reliability but rather needed for good business practices or to meet an agreed-upon sponsored project schedule, then it is anticipated that agencies will recognize the unique circumstance and be flexible if they can, including granting no-cost time extensions if needed. The investigator should reach out to the program officer as soon as a delay is anticipated.

Note that this applies to grants. For contracts requiring deliverables by a certain date, it may be possible to invoke the Excusable Delays clause. In any case, contractors should confer with their contracting officer about appropriate next steps as soon as a delay is anticipated. Council of Governmental Relations (COGR) recommends that investigators actively document their specific situations to provide a basis for any adjustments that may need to be requested when business returns to “normal” as well as the specific terms of an individual contract that may address this type of situation.

Q: Will agencies consider longer no-cost time extensions if they are needed to finish a project after disruption?

Researchers should document the actual impact of COVID-19 on the progress of their grants to provide substantiation for any future no-cost time extension request. It is not known at this time if agencies will consider longer-than-normal no-cost time extensions or multiple no-cost time extensions in this situation, but no-cost time extensions covered under expanded authorities will still be available for federal awards.

NIHNational Institutes of Health: The NIH Standard Terms of Award provide the recipient the authority to extend the final budget period of a previously approved project period one time for a period of up to 12 months beyond the original completion date down in the NoA. Any additional project period extension beyond the initial extension of up to 12 months requires NIH prior approval.

NSF: grants are eligible for a one-year grantee-approved no-cost extension and then further extensions as approved by NSF. If you foresee a need for NSF-approved extensions, you should include that information in your annual report and discuss the need ahead of time with the cognizant NSF program officer for your award. See the Proposal & Award Policies & Procedures Guide (PAPPG), Chapter VI.D.3, for additional information.

DOJ: In accordance with Part 200 Uniform Requirements (2 C.F.R. Part 200, as adopted by DOJ) and consistent with the DOJ Grants Financial Guide, most OJP awards may be eligible for one no-cost extension of up to 12 months.  If the grant has previously received a no-cost extension and an additional extension will be requested due to the extenuating circumstances, refer to the DOJ Grants Financial Guide for additional information and consult with your grant manager as needed.

Please note that awards funded by the Office for Victims of Crime (OVC) (or any other OJP bureau/program office) under the provisions of the Victims of Crime Act (VOCA) of 1984, are available during the federal fiscal year of the award, plus the following three fiscal years. OVC and other OJP bureaus/program offices have no discretion to permit extensions of any award’s period of performance beyond the statutory period.

 Q: I can’t get to my research site and my research will be severely impacted. Will the sponsor provide incremental funding and/or additional time so that I can successfully complete the aims of the award?

We expect federal agencies will recognize the difficulties inherent in this situation and work with institutions to facilitate the conduct of the project. As a reminder, Faculty should reach out to their SP RA to discuss, if appropriate the SP RA will  (1) inform their program officer and grants officer that prior approval is required if the need arises for additional Federal funds to complete the project (200.308.(c)(1)(viii)) and (2) notify the federal agency as soon as “problems, delays, or adverse conditions which will materially impact the ability to meet the objective of the Federal award” (200.328.(d)(1)) are known.

In the latter case, the notification must include a statement of the action taken or contemplated and any assistance needed to resolve the situation. It is possible that there will not be an immediate answer on what is needed to resolve the situation; in that case, recipients should simply indicate that they will report back when more is known.

Per NIH FAQs on NOT-OD-20-086: NIH understands that travel restriction may continue to occur through the remainder of the public health emergency and will likely affect the progress of NIH-funded research. Recipients must contact the funding IC to alert them of the delays. NIH is committed to working with its applicants and recipients during this public health emergency.

Q: What do I need to know about COVID disruptions to work and "idle time"?

Refer to this May 11, 2020 Memo about idle time documentation and funding.

Q: How do I submit Personnel Activity Reports (PARs) while working remotely?

The PAR deadline is Friday, April 10^th.  We always accept electronic signatures but starting Thursday, March 12^th through Friday, April 10^th, we will also accept approval via email from the BU Employee directly or from the PI/Supervisor on behalf of any non-faculty or Student BU employee.  This will assist individuals who work remotely and do not have access to scanners and/or electronic signatures.  Please note that the percentages on the PAR must be filled out and total to 100%.

Please ensure all PARs are sent to us via our email box:  effort@bu.edu

Q: What do we do if Research Staff are unable to work in the Lab and are paid from Sponsored Funds?

Decisions on salary allocation on Sponsored Funds for individuals unable to work is ultimately up to the awarding agency.  BU is monitoring and communicating with Sponsors and while we have heard from our most prominent Sponsors, we have not heard from every Agency. The below information is provided as guidance with specific sponsor information.

Per Boston University policy, if an employee is paid from Sponsored Funds, regardless of on or off site, and is either using sick, vacation, or FMLA time during this period of COVID-19, the Sponsored Project should continue to be charged.

If a BU employee (staff, faculty, or PhD track student) is healthy but is considered non-essential personnel and therefore, due to reductions in research in response to COVID-19, is unable to perform their job duties in BU Labs/space or off-site, their salary should continue to be allocated to the Sponsored Award at the same effort distribution work was assigned. We are continuing to reach out to specific sponsors to determine their approach during this crisis and will continue to update this FAQ. Please see below for links to guidance from our largest Awarding Agencies and the Office of Management and Budget (OMB). Please contact your PAFO Research Administrator for specific questions.

For BU undergraduate and graduate students (not including PhD track students) that are unable to work due to restrictions in research activity due to COVID-19 (including an inability to work remotely), the Student Employment Office has released guidance that students will be furloughed and paid either two weeks of continuation pay or, if you are a Work Study student, the balance of their Work-Study award in one lump sum.

OMB

Notice M-20-17 entitled “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations.” The memo noted “Awarding agencies may allow recipients to continue to charge salaries and benefits to currently 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.”

Sponsor Guidance

Individual sponsor guidance is being maintained at Research Support’s website at https://www.bu.edu/research/2020/03/24/sponsor-guidance-and-agency-responses-to-covid-19/

 Q: On March 15, the State Department issued a travel advisory raising all countries outside of the U.S. to a Level - 3 “Reconsider Travel” status. If researchers choose to travel abroad (e.g., to fulfill a grant responsibility such as present a paper or attend a meeting to discuss research) although their institution has advised against travel to that country, can salary still be charged to the award – even if they need to stay in the country longer than originally anticipated?

Travelers should follow BU policy. If such travel is critical, obtain an exception in advance. BU has issued a memo regarding travel which can be found here.

Q: Can salary continue to be charged if a researcher is on multi-day self-isolation period? Does it matter if the researcher is able to continue to work on the project from the self-isolation site (e.g. home or designated facility) or is unable to work (e.g., because the work must be done in a wet lab or field site?). Does it matter whether the self-isolation is self-imposed, institution-imposed, or government-imposed?

If the traveler is following BU-imposed or government-imposed self-isolation requirements, salary support will be continued as allowed under BU’s policy. Federal agencies have not yet issued guidance on this particular topic so you must be able to identify these transactions if federal guidance determines such costs are unallowable.   Sick time, vacation time and/or paid administrative leave may be taken if permitted by BU’s policy. If the researcher is able to work from home, Q.1 under Remote Work Environments should apply.

Q: If schools or elder-care facilities close, can award-funded employees stay at home to do child-care and eldercare and still charge their salary to a grant?

If an award-funded employee stays home due to a school or facility closure for child or elder care needs, the employee’s salary would be charged in accordance with BU leave policy. As provided for in 2 CFR 200.431 Compensation – Fringe Benefits (a), the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, non-Federal entity-employee agreement, or an established policy of the non-Federal entity.

Please note that this may not be allowed under all Sponsors.

Q: If the agency program officer or grants officer is unavailable (or if the agency is closed) due to COVID-19, can grant personnel continue to work and charge salary to the project?

Grantees should be able to continue work until their period of performance and funding is exhausted. If prior approvals are required, Sponsored Programs will continue to submit their request to the funding agency electronically. If approval is not forthcoming, Sponsored Programs will consult with the PI on whether to proceed with the action for which approval was requested, understanding that any costs associated with that change may need to be absorbed by the department if approval is not subsequently granted.

For cooperative agreements and contracts that require agreement or contracting officer approval, the risk is likely to be higher. If some projects may not be able to proceed fully or at all, document the situation where work needed to slowdown or stop to help guide agency approval requests (time extensions, supplemental funding) once work resumes.

DOJ: Grantees (and subrecipients/subgrantees) should review the DOJ Grants Financial Guide and the Part 200 Uniform Requirements (2 C.F.R. Part 200, as adopted by DOJ) (see, for example, 2 CFR 200.430 and 2 C.F.R. 200.431, under Subpart E – Cost Principles), and BU (or subrecipient’s/subgrantee’s) established policies, to help determine how the grantee’s personnel costs may be treated during any interruptions to the work under the award.  Direct any questions about allowable costs to your OJP grant manager, or to OJP’s Office of the Chief Financial Officer by calling the Customer Service Center at 1-800-458-0786 (TTY: 202-616-3867), or via email at ask.ocfo@usdoj.gov.

The Office of Management & Budget (OMB) released guidance to federal agencies on March 19^th allowing a number of flexibilities for the research community including the allocation of idle time to research awards. University Leadership sent a memo to all faculty noting that per OMB memo M-20-26, idle time on grants can continue to be charged on BU sponsored awards through September 30, 2020. 

Moving forward, faculty who utilize the flexibilities provided by the OMB memo and their funding agency must document any additional funding sources available to them and provide a reason why these sources are not being used to offset costs. Sponsored Programs and Post Award Financial Operations have created a simple template that can be used to produce this required documentation. Please note, this is only necessary for research taking advantage of this flexibility after June 18, 2020.

These FAQs address the documentation needs regarding idle time that is allocated to an award. The tracking sheet for indicating idle time can be found here: https://bushare.sharepoint.com/sites/BU-COVID-Research-Time

Internal

Q: Why are we doing this?

PAFO is requesting information from PIs about time tracking of idle time for compliance purposes. In addition, Boston University is audited annually under Uniform Guidance and we believe this documentation will be requested as part of that audit. 

Q: How do I know if I have idle time?

Idle time on research is defined as time that you were unable to work on your research due to disruptions from COVID-19. A common example of this is the inability to continue work due to a lab shutdown.  That being said, as with every aspect of our lives over the past two months, most research projects have experienced some amount of disruption. For example, the particular activities conducted during the months of March and April were likely different than those originally planned (e.g. changes in activity due to cancelled travel or delayed recruitment). Additionally, even in the absence of a pandemic, there is always some amount of month-to-month variability during any project period. This type/degree of disruption is much different than the “Idle time” that PAFO is requesting. If you and your research team were able to continue progress on your award and the time spent on the project was generally consistent with the planned salary allocation within the bounds of normal month-to-month variability, then it is appropriate for you to report the time as “Active.”

Q: Do I need to track weekly employees who submit time through the SAP system?

For Non-Exempt Hourly staff you do not need to indicate their idle time on the tracking system if they are actively using the "Department Closure” code (2033) when submitting their weekly time. All weekly employees should be using the “Department Closure” code and will be expected to do so from May 1 onwards. 

Q: How is this different than effort reporting? Do we still need to do effort reporting every 6 months?

Effort reporting is a separate and distinct process that provides an indication of the level of effort on a research award. This exercise is evaluating the impact of COVID-19 on our ability to execute research and does not replace effort reporting. Idle time indications should be used when significant disruption is incurred while effort reporting is confirming the effort on an award over a 6 month period.

Q: Is the expectation that PI’s or grant managers reach out to project staff for their effort estimates?  

No. We realize that there will be a level of disruption but as this is not a certification of effort. Detailed effort estimates should be reserved for the effort reporting process (i.e. PARs). This exercise is just to track idle time and determine the level of COVID disruption. We expect that most researchers have been able to continue research in some form and can simply list “Active” where work is continuing.

Q: Once this information is reported, will grants managers be informed to adjust payroll accordingly?

As PAFO and Sponsored Programs gather allowability of idle time information from Sponsors, departments will be notified directly if salary has to be moved; until then, no salary should be moved outside of the normal effort reporting process.  If a PI hears from a Sponsor that idle time is not allowed, please let Gretchen Hartigan (hartigan@bu.edu) and Diane Baldwin (dbaldwin@bu.edu) know.

Q: Is it allowable to anticipate that any reduced effort in March/April can be recovered by increased effort in May/June?  

If reduced effort in March and April will essentially be recovered via increased effort in May and June, then for the purpose of this reporting exercise, the work did not experience a COVID-related disruption and the allocation should be reflected as “Active.” “Idle” time indicators should only be used to show COVID-related disruptions that will not be recovered in the coming months.

Q: Should COVID-related sick time or vacation time be reflected?  

COVID related sick time or vacation time is just like regular sick time or vacation time and should be listed as Active in this exercise.

Q: Will this reporting be required or updated for May and (if necessary) subsequent months?  

Yes. As the OMB guidance is applicable this exercise will be required.

Sponsors

Q: Should PI’s now communicate with sponsors who may require prior approval or those not allowing pay for idle or reduced time? Will Sponsored Programs contact sponsors about idle time?  We do not recommend PI’s proactively reaching out to sponsors without first coordinating with their SP RA to determine if prior approval notification is required or if idle or reduced time is covered by OMB flexibilities. If PI’s are receiving notification from their sponsors, please forward that correspondence to Gretchen Hartigan (hartigan@bu.edu) or Diane Baldwin (dbaldwin@bu.edu) so they can coordinate the response.  Once the data collection on the idle time has been completed, SP and PAFO will be reviewing that to determine which sponsors will need to be contacted about idle time approval.

Q: Will departments be required to confirm Sharepoint info is consistent with previously submitted RPPR’s, progress reports/invoicing, or match with PO/sponsor expectations?

No, not for previously submitted RPPRs or progress reports. However, the information should be consistent with RPPRs and progress reports moving forward. Allowable idle effort charged must be reported in sponsor reports as well as the COVID-19 impact or disruption on projects.  It should be noted that the SharePoint changes will not be fed back into Payroll.

Q: If effort is reduced in March and April, can we assure sponsors that during reboot/ramp-up effort will increase similarly (May onward) to meet project annual effort commitment?  

Yes, but if your report idle time and the Sponsor does not allow idle time, you will still have to remove any March/April idle time from the grant. As described above, if reduced effort in March and April will essentially be recovered via increased effort in May and June, then for the purpose of this reporting exercise, we can feel comfortable considering this time as “Active.”  If you are changing effort for the period that should go through the normal request process for salary allocation changes.

Q: Will this information be required to be reported to us by our subrecipients?  Should (Prime) PI’s be contacting their collaborators?  

We are assessing what a process/communication to our subrecipients needs to look like. Subrecipients should continue to submit progress reports to the BU PI as required in the sub agreements issued by BU and we expect any COVID impacts or disruptions should be noted there so that the BU PI may incorporate this information in the overall progress report to the sponsor.  BU PIs should be in regular communications with their subrecipient collaborators as to the progress of the project and we do not suggest any specific outreach to their collaborators at subrecipient institutions, but if they receive information, please share with their sponsored programs RA.

Q: How does BU normally set its fringe benefit rates with the federal government?

Fringe benefits are non-salary costs associated with compensation for employees, including health and retirement plans. On a biannual basis, BU sets its fringe benefit rates for two-year periods to allocate fringe benefit costs on federal grants. BU estimates fringe benefit rates at the beginning of each fiscal year based on prior two-year fringe benefit actuals expenditures (BU’s fiscal year is July 1 to June 30). At the end of the fiscal year, a reconciliation is done between the University’s actual fringe benefit expense and the assessment of fringe benefit expense, any difference in the estimate and actual expenditures is applied to future years and future fringe benefit rates (i.e. “carry forward,” also known as over/under recovery). Fiscal 2020 and Fiscal 2021 negotiated fringe benefit rates, for example, were based on Fiscal 2017 and Fiscal 2018 fringe benefit actual expenditures.

Q: Why is BU reducing its fringe benefit rates for FY21?

The elimination of the University’s contribution to the retirement fund will unexpectantly change our estimated fringe benefit costs for FY21. If BU does not reduce its fringe benefit rates, there will be a significant discrepancy between the current negotiated rate with the federal government and the actual fringe benefit costs, creating a large carry forward. That carry forward could have a negative impact on future rates. The Department of Health and Human Services (DHHS) presented us with an exception opportunity to lower the fringe benefit rates during these unique times.

Q: What is the timeframe for receiving and announcing the new fringe benefit rates for FY21?  

Boston University received approval from the DHHS on June 11^th to reduce our fringe benefit rates for FY21. Once the University processes the final approvals, the change will be officially announced to the BU community. The changes will be implemented into SAP before there is any undue burden on department and/or grant administrators. Check here for the updated rates following the official announcement.

Q: Do these fringe benefit changes apply to BU employees charged on BMC Sponsored Research awards as well?

Yes.

Q: Do I need to rebudget my award because of a lower fringe rate?

No, we are not requiring that you submit a re-budget to Sponsored Programs. The system will automatically charge the lower FY21 rate and the surplus in the fringe line can be used, as allowed by the sponsor, toward other cost categories in support of the project assuming it does not represent a change in scope.

Q: Do I require sponsor prior approval to repurpose the surplus in fringe benefits to other cost-categories for the project?

Most federal sponsors allow the reallocation funds without prior approval as long as the changes to do not result in a change of scope. For non-federal sponsors, it will be important to confirm what is allowable in the award agreement.  If you are unsure, please reference your award agreement or consult with your Sponsored Programs RA.

Q: What fringe benefit rates do I use if I am currently submitting a proposal for FY21?

Please reference our rate webpage here for current active rates. Please use the active fringe benefit rates in proposal submissions.

Q: What will the fringe benefit rates be in future years after FY21? Will the fringe benefits costs be more in line with FY 20 costs?

BU received approval for provisional fringe benefit rates for FY22 as part of our proposal to DHHS. The FY22 submission is based on the FY19 and FY20 benefit costs and therefore includes the University’s retirement contribution resulting in a fringe rate similar to the FY20 rate. The provisional fringe benefit rates will be officially announced along with reduced fringe benefit rates and updated on our rate webpage found here.

Q: What fringe benefit rates do I use in my proposal after the FY21 rate and FY22 provisional rates are approved?

This depends on when the research will be taking place. If you are submitting a proposal that includes starting work in FY21 and continuing work in FY22 your proposal budget should include both the FY21 and FY22 rates. This adds a level of complexity to your budgets as you are calculating fringe based on two different rates for the period of the research.

As an example, if you are submitting a one year proposal where research will begin on 1/1/21 and end on 12/31/21 you must calculate the fringe for the period of 1/1/21 to 6/30/21 using the FY21 rate and for the period of 7/1/21 to 12/31/21 using the FY22 provisional rate.

Q: What fringe benefit rates do I use if I am submitting a proposal for FY22 and beyond?

You should reference our active rate webpage found here for the most up to date rates. Following the approval of the new rates, if all research is taking place in FY22 or beyond (starting 7/1/21) you will use provisional fringe benefit rates. These will be the fringe benefit rates you need to use for any proposals for FY22 and/or future grants.

See also: FAQs on business travel (including links to BU preferred travel agencies, current travel advisories, airlines, etc.)

Q: Are travel cancellation costs due to COVID-19 allowable as direct charges to sponsored projects?

Through the release of NOT-OD-20-86, the National Institutes of Health (NIH) has stated nonrefundable costs associated with grant-related travel that has been canceled due to COVID-19 may be charged to the NIH award if they would have otherwise been allowable.

For all other federal agencies, guidance has not yet been released. Boston University’s policy (including policies established for COVID-19 or other emergencies) allows for travel cancellation costs to be charged to institutional fund sources, therefore we recommend that you also charge those same costs to sponsored projects to ensure consistent charging practices. To be allowable, it is reasonable to assume that the traveler has requested and been denied a refund, and that documentation of such a request is stored with the award files. We recommend that you document such transactions to allow for corrections if funding agencies issue guidance that is contrary to this practice. It should be noted that several airlines are waiving travel cancellation fees for at least the immediate future.

Q: How should credits from canceled travel costs be handled on sponsored projects?

If a traveler has charged (e.g., through prepayment or a travel advance) an airline ticket or other travel cost to a sponsored project, and then that trip is later canceled, the credit must accrue to the sponsored project (see 2 CFR 200.406). Some airlines are offering full refunds for trips that need to be canceled due to COVID-19; in these instances, the refund should accrue to the grant, either directly through the institution’s travel system or via reimbursement from the traveler. If a traveler cancels a trip and accrues a credit on their personal account, the traveler should follow BU policy for how to track and manage the credit.

Per NIH FAQs on NOT-OD-20-086: If vouchers have been granted for any of the travel expenses affected by COVID-19, recipients are required to use the vouchers and may not request additional support. BU Departments must document that costs charged to a grant are non-refundable and maintain documentation, following record retention requirements, and make them available to NIH upon request.

Procedure for e-credit
Flight charges may remain on the original account until the travel occurs. If charged to a university account, departments will track the e-credits. Preference is for the faculty members to use the e-credit for the same project before the airline deadline. If the traveler is unable to use the e-credit for the original project, the individual may potentially use the e-credit for other university travel. In cases when e-credits are used for a different project, the institution does internal cost transfer paperwork to the correct account. Documentation about the traveler’s inability to use the e-credit on the original project, and documented communication with program officers and/or vendors must be kept with cost transfer documentation. If a PI has already charged the airline ticket to their own credit card, the university will reimburse via a discretionary fund tagged for COVID-19-related costs.

• The travelers are encouraged to use the e-credit for the same project within the airline deadline to use e-credits.
• If the traveler is unable to charge the original grant project, internal cost transfer paperwork is done to transfer to the correct account.
• Reason(s) stated for using this method: reduction of journal paperwork upfront with emphasis on documenting communication.

Q: What do you know about accommodations airlines are making because of COVID-19?

Various airlines have announced special accommodations, including waiving all or certain change fees. This list is not comprehensive, and policies are subject to change at any time. Travelers should consult the airline’s website directly for the most up to date information:

Delta (updated 3/10/20) – Waiving change fees for all flights from March 1 – April 30, no change fees for all tickets purchased between March 1 – 31 and certain other international flights beyond that time. See https://www.delta.com/us/en/advisories/other-alerts/coronavirus-travel-updates 

United (3/12/20) – Waiving change fees for all flights between March 3-31 and for tickets purchased before March 3 for flights from March 9-April 30. A comprehensive table of waived change fees for specific airports/periods of travel is available at https://www.united.com/ual/en/us/fly/travel/notices.html 

American (3/15/20) – Waiving change fees for all new non-refundable tickets purchased before March 15, 2020, or are scheduled to travel March 11- May 31. See https://www.aa.com/i18n/travel-info/travel-alerts.jsp for more details.

Q: If a traveler can return home from travel (domestic or foreign) but at a much greater cost than usual, is the additional cost allowable on the grant?

The traveler should follow BU’s policy for emergencies.  BU Travel Policy can be found here: http://www.bu.edu/policies/6-4-1-travel-and-business-expense-policy/

BU’s policy or practice related to the criteria for evaluating the status and extent of the emergency and the level of relief that is considered appropriate to those circumstances should be followed.

Per NIH FAQs on NOT-OD-20-086: As outlined in the NIH GPS 7.9.1, travel costs are limited to those allowed by formally established organizational policy, and in the case of air travel, the lowest reasonable commercial airfares must be used. Recipients should continue to comply with their institutional travel policies to determine the allowability of these costs in cases of unforeseen or emergency circumstances.

Q: Can travel insurance be charged to grants?

The traveler should follow BU’s policy for emergency situations. BU does not permit people to buy insurance (nor charge to grants) as we are covered under BU’s insurance coverage for employees and vehicles.

http://www.bu.edu/policies/6-4-1-travel-and-business-expense-policy/

Q: I am a PI on a very large Program Project Grant, which includes hosting a conference in Atlanta with hundreds of collaborators participating from around the world. I have already incurred $35,000 of expense for the rental space at the convention center and hotel. I am working with the venue to get a credit but there will be a sizeable cancellation or penalty fee. Can I charge this to my award? And can I pay the travel fees and any associated costs for the hundreds of collaborations that were planning on attending?

1. Does it matter if I elected to cancel it because it was prudent to do so?
2. Does it matter if it was in a CDC level 3 location?
3. Does it matter if my institution is not allowing it?

Federal agencies share institutional concerns about the safety of researchers. If the PI (organizer) believes it would be unwise to hold the conference, the organizer should confer with the program officer and grants management specialist to decide whether to cancel the meeting, postpone the meeting, or convert the meeting to an on-line format. This request for input is consistent with 2 CFR 200.407 which says in part: “the non-Federal entity may seek the prior written approval of … the Federal awarding agency in advance of the incurrence of special or unusual costs.” Note that if the request is made orally, written documentation of the decision should follow (an email from the agency to the PI should be sufficient). Note that for many federal agencies, the program officer cannot independently make this type of decision, and grants office concurrence is required. PIs should follow the requirements for their specific agency. In the course of the discussion with the funding agency, it would be appropriate to discuss the basis for the proposed cancellation (prudent circumstances, CDC level 3 location, or institutional determination that travel will not allow the organizer to attend.) Organizers may wish to make a firm decision about keeping or canceling the meeting early enough to enable their participants to take advantage of discounts offered by airlines or hotels related to COVID-19 changes or early cancellation deadlines (particularly for hotels). Also, a decision by the organizer to cancel the conference may assist some participants in convincing their institution to pay their cancellation costs.

If a conference is canceled with the concurrence of the federal funding agency, the non-refundable costs for the venue may be an allowable charge to the project (if the project was scheduled to incur those costs in the first place). In general, the costs for participants should follow the funding stream intended to pay for their attendance; if the conference grant was reimbursing all or part of the participation costs for all attendees, it may be appropriate to also charge some or all of their cancellation fees. If participants were covering their own attendance costs (from sponsored or non-sponsored sources), then the cancellation costs should follow the sponsor funding their participation or the participant’s employer.

Per NIH Guide Notice NOT-OD-20-086: Scientific meetings, conferences, and workshops supported by NIH funding may be delayed or canceled due to COVID-19. Non-refundable costs associated with NIH supported meetings and conferences affected by COVID-19 are allowable and may be requested as an administrative supplement to the appropriate funding IC. Recipients should contact their assigned grants management specialist and program official to provide documentation demonstrating the effect of COVID-19. The funding institute or center will work with the recipient to address the impact on the NIH Grant.

Q: I am a PI on a sponsor-funded Conference or Travel award, but the meeting has been canceled. Who do I contact regarding the impact to the award? 

National Science Foundation (NSF): You should contact the cognizant NSF program officer about this situation. In light of the public health threat, you may wish to consider alternate plans, such as providing or using options for virtual participation. Also, NSF program officers will be open to rescheduling the conference or using the funds for a future meeting that is consistent with the original scope and objectives of the award.

Department of Defense (DOD): You should contact the cognizant USAMRAA grants official named in the award document to alert them to the situation. Also, copy the program official to ensure all appropriate federal staff is aware of the circumstances. In light of the public health threat, you may wish to consider alternate plans, such as providing or using options for virtual participation.  Additionally, it may be possible to attend if the meeting/conference is rescheduled within a year.  See the question above regarding one-time no-cost extensions.

For meetings that are specified directly in the application or award notice, or that have been required by the Congressionally Directed Medical Research Program (CDMRP) (e.g. Milestone Meetings, In-Progress Reviews, etc.), we will be open to rescheduling the meeting or setting up a virtual presentation.

Q: A conference has been canceled, but I have nonrefundable travel and/or hotel costs. Can these costs be charged to a Conference or Travel grant? 

Please follow all BU Relevant Policies and Procedures, including the BU Travel Policy here: http://www.bu.edu/policies/6-4-1-travel-and-business-expense-policy/

 Q: I am considering submitting a Conference or Travel proposal for a future meeting. The site of the meeting has not yet been selected; should I take into account COVID-19 in conference planning and site selection?

Travel logistics, accessibility, and health and safety considerations of the participants should always be a foremost consideration in any Conference proposal. Since the COVID-19 threat is still evolving, it is important to consider flexibility and alternative plans in a proposal to support travel or a conference. For foreign travel, you should consult the State Department Travel Advisories website.

Q: What should we do about the Department of Justice (DOJ) related conferences, events, and other gatherings?

For Office of Justice Programs (OJP)-sponsored conferences, meetings, training, and other gatherings that are scheduled in the near term, cooperative agreement recipients should work with their OJP program or grant managers to set up meetings as virtual events or postpone or cancel meetings. For events planned farther out, please work on a case-by-case basis with your grant manager.

Grantees should contact their OJP grant managers to address issues resulting from postponed or canceled meetings, such as using grant funds to cover hotel or travel-related cancellation fees and penalties.

Grantees should try to have the airline reimburse the canceled ticket(s) in cash. However, if the airline will only refund the cancellation as a credit:

• The grantee should apply the credit to a future trip for the same OJP grant or project.
• If that is not possible, the grantee should use the credit for another OJP program or project and reimburse the original OJP grant or project with the equivalent dollar amount.
• If neither of those options is possible, then the grantee should process the trip as a cancellation, which OJP approves to be charged to the grant due to this mitigating circumstance.

Grantees should provide similar guidance to sub-recipients (that is, subgrantees). Please document these such changes via a Program Office Approval Grant Adjustment Notice (GAN) in OJP’s Grant Management System (GMS) for record-keeping purposes.

Are Sponsored Programs and Post Award Financial Operations staff working?

Yes. Sponsored Programs (SP) and Post Award Financial Operations (PAFO) staff are all working remotely. They are receiving emails and calls to their office phones are being forwarded to their cell phones. Proposals are being submitted daily and are the priority of SP. Mail is being checked periodically but wherever possible we ask that communication be sent electronically. Given the situation, it is increasingly important that you adhere to BU’s proposal submission policy by submitting your complete and final proposal at least 3 business days in advance of the sponsor deadline as we may need to coordinate across our teams. We are already experiencing system submission issues. Late proposals will be addressed in the order they are received. If you call the main SP (353-4365) and PAFO phones (353-4555) you will be able to leave a message for the Administrative Coordinators or you can use the phone tree and type in the first three letters of the persons last name you are trying to reach. These calls will go directly to our cell phones.

Q: How can I order equipment or supplies to my home address while working remotely?

Refer to Sourcing & Procurement guidance: https://www.bu.edu/sourcing/covid-19-updates

Shoppers should continue to follow IS&T and BU Sourcing & Procurement guidelines and order from one of our contracted IT suppliers for computers and peripherals. We encourage the use of the Terrier Marketplace where IS&T standards (configured machines) are available to order.

During this remote work situation, we are allowing ship-to-home with a financial administrator’s approval. Add a note to shopping carts that the delivery address is not the usual address.

Audit will be running reports against home delivery addresses to ensure the assets are returned to campus.

Q: Where to send checks?  

A: Payments to Boston University for reimbursement of sponsored research awards should still be sent to our lockbox address below:

Boston University Grants Receivables

P.O. Box 28763

New York, NY 10087-8763

Additionally, ACH payments can be made for payers within the U.S. Please contact Missy Downs, Director of Research Finance at 617-358-5114 for ACH instructions.

Q: Research studies with a lab component already purchased gloves. Who would pay for other supplies (masks, wipes, etc.), if needed?

Please reach out to your PAFO RA to discuss. Subject to your institutional policies, personal protection equipment needed to perform the grant may be a direct charge. Supplies needed for general cleaning should be covered by a non-grant or departmental account.

Q: If staff would need to work from home, we are considering cell phones for use when contacting human subjects since some people are uncomfortable with using their personal phones when calling human subjects or research study participants. Depending on the research study, it could be from one to three to several cell phones needed. What alternatives do they have?

Please reach out to your PAFO RA to discuss. Inexpensive cell phones used solely for the purposes of the grant would appear to be a defensible charge to the grant in these circumstances. The PI/department authorizing the charges would need to oversee the purchases and use of the phones to ensure that they were used exclusively for the project; if used for multiple projects, cost allocations must reflect relative usage. Obtain prior approval from your institution if its policy prohibits the reimbursement of cell phone charges. Documentation should be retained in the department’s grant file. In addition, the department may want to consider alternative technologies that allow users to shield their personal number when using their own cell phone for business purposes. For example, see Google Voice:

How it works: https://www.lifewire.com/how-google-voice-works-3426682

Link to the app: https://voice.google.com/u/0/about

Important Note: In the context of human subjects research, we want to remind the research community that Google Voice for consumers is not HIPAA compliant and should not be used for research projects subject to HIPAA requirements.

Q: Reminder calls to research study participants to stay home if they are sick are already taking place. Some of our research study participants are older and more vulnerable. Emails from my institution have reminded employees to stay home if sick. Can I charge unexpected costs that may arise to the grant? (For example, additional labor charges for time spent calling study participants).

Costs to projects related to contact with study participants (to guide their participation or to make arrangements for alternate plans) are allowable costs to the project. If the volume of such work involves a significant amount of additional labor charges, investigators can consider requesting supplements from their funding agency. It will be important to document the actual additional cost in these circumstances to guide requests for supplemental funding or additional time.

Q: DOJ - Will programmatic and financial monitoring continue?

Until otherwise notified, all planned on-site monitoring will be conducted as remote monitoring or postponed for a later date. You will be contacted by your OJP grant manager and/or financial staff of OJP’s Office of the Chief Financial Officer to make alternative arrangements. If your organization is unable to participate in remote monitoring due to operational limitations, you may request postponement until a later date.