Guidance on Research Funding During On-Campus Shutdown

  • Suggestions on Flexible Work Assignments: If graduate students, postdocs and other researchers paid from federal research awards can continue to work on their research projects remotely, then in general, their salary can continue to be paid from the federal awards.  Researchers could engage in a variety of activities that do not require access to specialized facilities, such as manuscript writing, data analysis, maintenance of tissue/cell banks, maintenance of specialty equipment, cataloguing and organization of data, analysis of experimental designs and plans for future methods and experiments.  If, however,  an employee cannot successfully work from home (e.g., the nature of their duties requires them to work on-site or they do not have home Internet or access to a computer) and alternate duties that benefit the project cannot be creatively identified, then the direct charge of their salary to the award may not be appropriate depending on the source of funds.
  • Remote-Work Considerations: Researchers should not take materials other than laptops, data storage devices, etc., offsite (e.g., to their homes) to ensure research continuity during a curtailment. All laboratory research must continue within the confines of appropriate laboratory space. More leniency is allowed in the cases of information technology and work furniture but please understand the serious responsibility we have to the safety of our researchers and the security of our property.  Please note that if a researcher needs to access a data set from home that contains sensitive or private information in order to keep working on a project, the researcher must have secure access to the data set before accessing it remotely. Researchers should work with their IT departments to explore whether a secure remote access option is viable for their project as well as the type of data that may be subject to a potential breach. If secure access to the data set is not possible (e.g., remote access via VPN or other means), then a risk analysis should be performed to determine if the data set should be accessed. Researchers should document the period they were unable to work on the data set for the purpose of determining if they later need to request a no-cost time extension.
  • Remote Work Outside of the U.S.: Researchers who want or need to work temporarily for the University of California from a different country should contact the Academic Personnel office (faculty, postdocs and other non-student researchers) or the Graduate Division (graduate student researchers) for guidance.  Please also inform your SPO team as soon as possible of your overseas remote work arrangement so that we can ensure compliance with all sponsor policies and federal rules.
  • Administrative Leave: If remote research is not feasible, in accordance with President Napolitano’s Executive Order signed on March 16, 2020, postdocs and students are eligible for 128 hours of paid administrative leave.  See the president’s Executive Order for more details. Principal Investigators may have the opportunity to apply for administrative supplements to provide additional funding for salaries. We suggest PI’s contact their Program Officer to inquire about supplemental funding.

Overarching Guidance from the Office of Management and Budget

The Office of Management and Budget (OMB) serves the President of the United States in overseeing the implementation of his vision across the Executive Branch. Specifically, OMB’s mission is to assist the President in meeting his policy, budget, management and regulatory objectives and to fulfill the agency’s statutory responsibilities.  OMB has issued several important memos to the federal granting agencies: Memo M-20-11, M-20-17, M-20-20, M-20-21, M-20-22, M-20-23, M-20-26, M-20-27 directing them to provide flexibility to recipients affected by the loss of operational capacity and increased costs due to the COVID-19 crisis. OMB Memos M-20-17 and M-20-20 expired on June 17th, and the flexibilities that were provided in those memos no longer apply. OMB Memo M-20-26 provides a limited extension of two specific flexibilities and expires on September 30, 2020.

COVID-19 Relevant Policies from Select Federal Agencies

Sponsor-specific guidance related to the response to COVID-19  is rapidly changing. All charges incurred on sponsored projects during this time must be tracked and justified in case of an audit, which may come years from when the expense is incurred. Please be prepared to transfer charges off awards if future sponsor guidance indicates that any of the items charged are no longer allowed.

At this time federal sponsors have not released solicitations or guidance encouraging submission of supplemental applications for projects affected by COVID-19.  Project budgets should be revised (if allowable per the terms of the award) to integrate COVID-19 related expenses and there should be no expectation that additional funds will be provided by the sponsor to cover any shortfall. If possible, investigators should wait until the full extent of the impact on their projects is known before considering whether supplemental funding will be needed. If a shortfall of funds is anticipated, investigators should contact the program officer listed on their award to discuss the impacts on the project and possible solutions. Please contact the Sponsored Projects Team with any questions about supplemental funding.

Please be advised that an assessment regarding the allowability of costs must be made on a case-by-case basis. Please contact your Sponsored Projects Team for any questions that are related to a specific proposal or award.

The guidance provided covers grants and cooperative agreements from UCSB’s four largest sponsors: the National Science Foundation (NSF), the National Institutes of Health (NIH), the U.S. Department of Energy (DOE), and the U.S. Department of Defense (DoD) agencies. Please note that this guidance may not apply to contracts. For guidance from other sponsors, please click on the specific agency under Additional Notices from Federal Agencies below.

National Science Foundation
 

The NSF has extended deadlines for these specific programs: NSF Extended Deadlines. All other deadlines remain the same. Please contact the cognizant NSF program officer if an extension is needed for a program that is not listed.

UCSB has the authority to grant the first 12-month extension (Grantee-Approved NCE) and can request a second extension, beyond the first 12 months, if needed. Please contact your Sponsored Projects Team if you need either of these extensions.

  • Charging Salary for Remote Work: If the individual is able to work remotely and perform the tasks that were originally planned, their salary may be charged to the grant as long as the original scope of the project is not changing. Please contact your Sponsored Projects Team if the remote work will take place at a foreign location. NSF may need to approve the addition of a foreign performance site. 
  • Charging Salary Without Work: If the individual cannot contribute effort to the project while working remotely, the NSF will allow salary to be charged for the length of time that matches our institution's policies. Currently, UC Policy allows for 16 days of administrative leave as a result of COVID-19. If the charging of administrative leave to the award results in a shortage of funds needed to carry out the event or travel, do not assume NSF will award supplemental funding. The cognizant NSF program officer should be contacted right away if a shortfall is anticipated. 

If you expect the human and/or animal subjects portion of a project needs to be modified the first step is to contact the appropriate Research Integrity Specialist regarding the change.  For human subjects, please visit Research Integrity’s COVID-19 Impact on Human Subjects Research webpage. Next, the investigator should assess whether the original project goals and objectives need to be altered because of the change to human and/or animal subjects. Any changes to the original project goals and objectives require prior approval from the NSF. Please contact the cognizant NSF program officer right away if a change to the project scope is expected. If it is determined that a change in scope is needed, an official request for approval will be required. Please contact your Sponsored Projects Team to request official approval.

National Institutes of Health (NIH)

 

UCSB has the authority to grant the first 12-month extension (Grantee-Approved NCE). An extension beyond the first 12 months will require NIH approval. Please contact your Sponsored Projects Team if you need either of these extensions.

Please review NIH’s COVID-19 FAQ for the most up-to-date guidance regarding project personnel who are working remotely in a foreign country that was not listed in the original submission. Please contact your Sponsored Projects Team with questions or requests for prior approval.

  • Charging Salary for Remote Work: If the individual is able to work remotely and perform the tasks that were originally planned, their salary may be charged to the grant as long as the original scope of the project is not changing. If the remote work will take place at a foreign location that was not listed in the original proposal, NIH approval is required before the work can commence. Please contact your Sponsored Projects Team to submit the request to add the foreign performance location. 
  • Charging Salary Without Work: If the individual cannot contribute effort to the project while working remotely, the NIH will allow salary to be charged for the length of time that matches our institution's policies. Currently, UC Policy allows for 16 days of administrative leave as a result of COVID-19. Please note that the NIH program officer and grants officer must be notified and notification must be coordinated with your Sponsored Projects Team

NIH’s FAQ COVID-19 Flexibilities for Applicants and Recipients has a section for these programs. Please check the site often as updates are added regularly.

If you expect the human and/or animal subjects portion of a project needs to be modified the first step is to contact the appropriate Research Integrity Specialist regarding the change. For human subjects, please visit Research Integrity’s website: COVID-19 Impact on Human Subjects Research. Next, the investigator should assess whether the original project goals and objectives need to be altered because of the change to human and/or animal subjects. Any changes to the original project goals and objectives require prior approval from the NIH. Please contact the program officer on the award right away if a change to the project scope is expected. If it is determined that a change in scope is needed, an official request for approval will be required. Please contact your Sponsored Projects Team to request official approval.

Department of Energy (DOE)

Includes Advanced Research Projects Agency-Energy (ARPA-E) where indicated below.

 

UCSB has the authority to implement a 12-month extension (Grantee-Approved NCE). An extension beyond the first 12 months will require DOE approval. Please contact your Sponsored Projects Team if you need either of these extensions.

  • ARPA-E: UCSB does not have authority to implement an extension with ARPA-E awards. Awards that are active between 3/31/2020 and 12/31/2020 may be extended for up to 12 months. Please contact your Sponsored Projects Team to request an extension.
  • Charging Salary for Remote Work: If the individual is able to work remotely and perform the tasks that were originally planned, their salary may be charged to the grant as long as the original scope of the project is not changing. Please contact your Sponsored Projects Team if the remote work will take place at a foreign location. DOE may need to approve the addition of a foreign performance site. 
    • ARPA-E: The guidance above also applies to ARPA-E awards.
  • Charging Salary Without Work: If the individual cannot contribute effort to the project while working remotely, DOE will allow salary to be charged for the length of time that matches our institution's policies. Currently, UC Policy allows for 16 days of administrative leave as a result of COVID-19. If the charging of administrative leave to the award results in a shortage of funds needed to carry out the event or travel, do not assume DOE will award supplemental funding. The DOE program officer on the award should be contacted right away if a shortfall is anticipated.
    • ARPA-E: The guidance above also applies to ARPA-E awards.

If you expect the human and/or animal subjects portion of a project needs to be modified the first step is to contact the appropriate Research Integrity Specialist regarding the change. For human subjects, please visit Research Integrity’s COVID-19 Impact on Human Subjects Research webpage.  Next, the investigator should assess whether the original project goals and objectives need to be altered because of the change to human and/or animal subjects. Any changes to the original project goals and objectives require prior approval from the DOE. Please contact the program officer on the award right away if a change to the project scope is expected. If it is determined that a change in scope is needed, an official request for approval will be required. Please contact your Sponsored Projects Team to request official approval. 

  • ARPA-E: The guidance above also applies to ARPA-E awards.

Department of Defense (DoD)

 

  • DoD General Guidance: The DoD will support extensions to projects affected by COVID-19 but there may be funding restrictions that prohibit them from granting them. Please contact the grant manager if a no-cost extension is needed for award-specific guidance. 
  • AFRL: The Air Force Research Lab (AFRL) will consider approving 12-month extensions to projects that are active as of 3/31/2020 and scheduled to end on or before 12/31/2020. Please contact your Sponsored Projects Team if you need this extension. 
  • Charging Salary for Remote Work: If the individual is able to work remotely and perform the tasks that were originally planned, their salary may be charged to the grant as long as the original scope of the project is not changing. Please contact your Sponsored Projects Team if the remote work will take place at a foreign location. The sponsor may need to approve the addition of a foreign performance site.
  • Charging Salary Without Work: If the individual cannot contribute effort to the project while working remotely, the DoD will allow salary to be charged for the length of time that matches our institution's policies. Currently, UC Policy allows for 16 days of administrative leave as a result of COVID-19. 

If you expect the human and/or animal subjects portion of a project needs to be modified the first step is to contact the appropriate Research Integrity Specialist regarding the change.  For human subjects, please visit Research Integrity’s COVID-19 Impact on Human Subjects Research webpage. Next, the investigator should assess whether the original project goals and objectives need to be altered because of the change to human and/or animal subjects. Any changes to the original project goals and objectives require prior approval from the DoD. Please contact the program officer on the award right away if a change to the project scope is expected. If it is determined that a change in scope is needed, an official request for approval will be required. Please contact your Sponsored Projects Team to request official approval.

In addition to the above, DoD has special approval requirements for human and animal subjects research:

Additional Notices from Federal Agencies

 

Additional Resources & Notices