Administrative Relief from the Office of Management and Budget Update.
Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations
On March 19th, 2020 OMB Issued Memorandum M-20-17 which provided short term relief regarding the administrative, financial management, and audit requirements under 2 CFR 200 for recipients affected by the loss of operational capacity and increased costs due to the COVID-19 crisis.
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On June 18th, 2020 OMB Issued Memorandum M-20-26 which rescinded M-20-17 and provided an extension for the following two flexibilities through September 30, 2020:
- Allowability of salaries and other project activities.
- Extension of Single Audit submission.
The flexibilities provided in the three memoranda are meant to provide short-term administrative, financial and audit requirements under the 2 CFR 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, without compromising Federal financial assistance accountability requirements. The flexibilities and current expiration dates are June 16, 2020 (for M-20-17 and M-20-20) and July 26, 2020 (for M20-11).
As the Country is now recovering from the Coronavirus pandemic and some areas are starting the re-opening process, the ramp-up effort is also starting for the performance of Federally-funded projects. In addition, during the Coronavirus pandemic, many recipients learned the capabilities and are now getting the experience to perform the objectives of the Federal programs remotely with limited access to their physical office. However, due to the uncertainty of the re-opening phase and the speed of the ramp-up effort, this memorandum provides an extension of item 1, Allowability of salaries and other project activities (item 6 in M-20-17) through September 30, 2020 and item 2, Extension of Single Audit submission (item 13 in M-20-17) through December 31 , 2020 to allow a responsible transition to normal operations. In light of the limited funding resources provided for each Federal award to achieve its own public performance goals, 0MB added restrictions to the flexibilities allowed in item 1, Allowability of salaries and other project activities.
Appendix A describes the two flexibilities extended under this memorandum to recipients affected by the loss of operational capacity due to the COVID-19 pandemic. All flexibilities provided in this memorandum are time limited and will expire on September 30, 2020. M-20-17 and M-20-20 are rescinded. M-20-11 expires on July 26, 2020.
As program managers are considering the extension of the administrative and financial relief, they should be prudent in their stewardship of Federal resources, which includes giving consideration to potential offsets-e.g., reduction in training and travel. In addition, agencies are reminded of their existing flexibility to issue exceptions on a case-by-case basis in accordance with 2 CFR § 200.102, Exceptions.
Questions regarding the above administrative relief provisions should be directed to the Office of Federal Financial Management at GrantsTeam@omb.eop.gov. 0MB will continue to provide updates and additional information as the situation unfolds. For the latest information, sign up for the Grants Community of Practice by clicking at: https://www.performance.gov/CAP/grants/