The Office of Management and Budget (OMB) has put out memos providing for exceptions and administrative relief in response to COVID-19.

M-20-11 Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19). This memo communicates OMB’s decision to relieve short-term administrative, financial management and audit requirements under 2 CFR 200, Uniform Administrative Requirements, Cost principles and Audit Requirements for Federal Awards. In accordance with 2 CFR § 200.102, Exceptions, OMB is allowing Federal agencies to grant class exceptions in instances where the agency has determined that the purpose of the Federal awards is to support the continued research and services necessary to carry out the emergency response related to COVID-19.

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. This memo expands the scope of M-20-11 to include recipients affected by the loss of operational capacity and increased costs due to the COVID-19 crisis. The allowability of exceptions are at the discretion of the Federal grantor and can be for COVID-19 and other grants. Some of the exceptions include:

• All SAM registrants with active registrations expiring before May 16, 2020 will be granted a one time 60-day extension.
• Awarding agencies have flexibility with application deadlines, providing no cost extensions, extension of reporting deadline requirements.
• 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 recipients who incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to the public health emergency, to charge these costs to their award without regard to 2 CFR § 200.403, Factors affecting allowability of costs, 2 CFR § 200.404, Reasonable costs, and 2 CFR § 200.405, Allocable costs. Awarding agencies may allow recipients to charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant. Documentation must be maintained.
• Awarding agencies may allow grantees to continue to use the currently approved indirect cost rates (i.e., predetermined, fixed, or provisional rates) to recover their indirect costs on Federal awards. Agencies may approve grantee requests for an extension on the use of the current rates for one additional year without submission of an indirect cost proposal.

M-20-20 Repurposing Existing Federal Financial Assistance Programs and Awards to Support the Emergency Response to the Novel Coronavirus (COVID-19). OMB is issuing a class exception that allows Federal awarding agencies to repurpose their Federal assistance awards (in whole or part) to support the COVID-19 response, as consistent with applicable laws. As an example of this flexibility, agencies may allow recipients to donate medical equipment (including, but not limited to, personal protective equipment, medical devices, medicines, and other medical supplies) purchased with Federal assistance funds to hospitals, medical centers, and other local entities serving the public for COVID-19 response. This class exception also extends to the donation of other resources (such as labor, supplies, and contract services) funded under Federal financial assistance to support COVID-19 emergency response activities.

M-20-21 Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19).

The memos can be found on OMB’s website at: https://www.whitehouse.gov/omb/information-for-agencies/memoranda/#memoranda-2019