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.
  • 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-20-22M-20-23, directing them to provide flexibility to recipients affected by the loss of operational capacity and increased costs due to the COVID-19 crisis. We expect federal agencies to issue new or revised guidance regarding the effects of the COVID-19 health crisis on sponsored awards. At this time we are waiting for the federal agencies to flow down the flexible administrative relief exceptions to universities as noted above. Federal agencies have been urged to release guidance that is uniform and consistent but each federal agency may choose to flow down these terms in different ways.

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.

All annual and final project reports due between March 1 and April 30, 2020 have been extended by 30 days. NSF cannot make any new or supplemental awards if the PI or any Co-PI(s) has an overdue annual or final project report. All annual and final reports must be submitted by the revised due date.

  • Donation of Personal Protection Equipment (PPE): The donation of PPE and other lab supplies to support efforts related to COVID-19 requires prior approval from the NSF. If an investigator wants to request approval to donate PPE they must specify the items or resources that will be donated and any expected impacts on the scope of the project. A request to change the objectives or scope may also be required. If the donation of PPE will result in a shortage of funds needed to carry out the remainder of the project, do not assume NSF will award supplemental funding. Please contact your Sponsored Projects Team to request 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. 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. 
  • Non-refundable Travel Expenses: Non-refundable travel costs for cancelled events may be charged to the NSF award if the event, travel, or other activity was needed to perform the originally-proposed work. If the charging of cancellation or other fees 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. Please contact the cognizant NSF program officer right away if a shortfall is anticipated.
  • Costs of pausing and restarting research activities: Costs of pausing and subsequently restarting research activities may be charged to the NSF award if the costs can be clearly attributed to the specific award. Documentation will be key with these expenses as they need to be inarguably needed because of COVID-19. If the charging of these costs to the award results in a shortage of funds needed to carry out the remainder of the project, do not assume NSF will award supplemental funding. Please contact the cognizant NSF program officer 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)

 

Funding Opportunity Announcements (FOAs) expiring on or before June 30, 2020 will be extended for 90 days. Standard NIH deadlines still apply but the NIH will accept all late applications with original due dates between March 9, 2020 and May 1, 2020 as long as they are submitted by May 1, 2020. For full details please review the NIH notice: NOT-OD-20-091: UPDATE: NIH Late Application Policy Due to Public Health Emergency for United States for 2019 Novel Coronavirus (COVID-19)

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.

If you are unable to complete or submit a report by the due date please promptly contact the grants management and program officials. Though NIH may accept late reports, any awards or funding increments that are tied to those late reports will be delayed until the reports are submitted and accepted by the NIH.

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.

  • Donation of Personal Protection Equipment (PPE): PPE and other lab supplies may be donated to support efforts related to COVID-19 and funds may be re-budgeted to replace donated items once the immediate urgency has passed. The NIH will consider administrative supplement requests for funds to replace donated PPE as long as the donated PPE was purchased with direct funds from an NIH award. Note that PPE purchased with indirect cost funds will not qualify for replacement with an administrative supplement. SPO is not aware that any PPE is purchased with indirect cost funds but a determination should be made at the department. There is no guarantee that NIH will provide additional funds to replace donated PPE.
  • 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
  • Non-refundable Travel Expenses: Non-refundable travel costs for cancelled events may be charged to the NIH award if the event, travel, or other activity was needed to perform the originally-proposed work. If a voucher is issued for any of the travel expenses the voucher must be used for future travel on the project. 
  • Costs of pausing and restarting research activities: The NIH has not explicitly approved these expenses. We will continue to monitor NIH guidance and update this section accordingly. Please contact your Sponsored Projects Team if you have any questions related to this topic.

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.

 

The DOE will consider extensions to application deadlines on a case-by-case basis. At times the DOE may extend the deadline for the entire funding opportunity. Please contact the program officer listed in the guidelines if an extension is needed. 

  • ARPA-E: ARPA-E has updated almost all deadlines. Please check ARPA-E eXCHANGE for revised due dates.

Revised budgets and public abstracts may be submitted through PAMS as soon as practicable. Please note that awards may be delayed due to late submission of these pre-award documents.

  • ARPA-E: ARPA-E has not commented on this topic.

Progress and annual report deadlines can be extended but only with DOE approval. Please contact the program officer listed on the award if an extension to a report deadline is needed. Any awards or funding increments that are tied to those late reports will be delayed until the reports are submitted and accepted by the DOE. 

  • ARPA-E: If a report is due between 3/1/2020 and 8/1/2020 ARPA-E will consider granting an extension of up to three (3) months. The investigator must contact ARPA-ECOVID19-Response@hq.doe.gov to request an extension to the report due date.

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.
  • Donation of Personal Protection Equipment (PPE): The donation of PPE and other lab supplies to support efforts related to COVID-19 requires prior approval from the DOE.  Please contact your Sponsored Projects Team to request approval.
    • ARPA-E: The guidance above also applies to ARPA-E awards.
  • 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.
  • Non-refundable Travel Expenses: Non-refundable travel costs for cancelled events may be charged to the DOE award if the event, travel, or other activity was needed to perform the originally-proposed work. If the charging of cancellation or other fees 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. Please contact the DOE program officer right away if a shortfall is anticipated.
    • ARPA-E: ARPA-E will determine whether these costs are allowed on a case-by-case basis. Please contact your Sponsored Projects Team if you need to charge these expenses to an ARPA-E award.
  • Costs of pausing and restarting research activities: Costs of pausing and subsequently restarting research activities may be charged to the DOE award if the costs can be clearly attributed to the specific award. Documentation will be key with these expenses as they need to be inarguably needed because of COVID-19. If the charging of these costs to the award results in a shortage of funds needed to carry out the remainder of the project, do not assume DOE will award supplemental funding. Please contact the DOE program officer right away if a shortfall is anticipated.
    • ARPA-E: ARPA-E will determine whether these costs are allowed on a case-by-case basis. Please contact your Sponsored Projects Team if you need to charge these expenses to an ARPA-E award.

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 consider extensions to submissions and encourages PIs to regularly check the solicitation in Grants.gov for updates. Please contact the program officer and grants manager if an extension is needed.
  • DARPA: Defense Advanced Research Projects Agency (DARPA) may consider extensions to submissions. Please review the guidelines (BAA) and identify the contact to whom questions should be submitted. Submit the request for the extension to that contact and include the rationale for the request and the suggested alternative due date.
  • USAMRAA: United States Army Medical Research Acquisition Activity (USAMRAA) does not currently plan to change any proposal due dates but encourages PIs to regularly check the solicitation in Grants.gov for updates.
  • ONR: The Office of Naval Research (ONR) is not extending upcoming application deadlines at this time. If ONR’s guidance changes they will update their FAQ and we will update this site.
  • 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. 
  • DARPA: DARPA will consider granting extensions. DARPA requests that the delay, the impact to the project, what caused it, what you did or have done to mitigate the delay, and any other relevant facts and details be documented. Please contact the contracting officer in writing and explain all the details of the situation, provide the documentation, and note that COVID-19 is one of the reasons that the no-cost extension is needed.
  • USAMRAA: UCSB has the authority to grant the first 12-month extension (Grantee-Approved NCE). An extension beyond the first 12 months will require USAMRAA approval. Please contact your Sponsored Projects Team if you need either of these extensions.
  • 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. 
  • ONR: ONR will provide a one-year no-cost extension to all grants ending between 3/31/2020 and 12/31/2020. Note that if the appropriation that funded the award is expiring an extension may not be possible. In those cases please contact your Sponsored Projects Team
  • DoD General Guidance: The DoD will allow grantees to delay submission of progress reports up to three months beyond the normal due date.  For any other deliverables related to research awards, please contact the grants manager and/or program manager for award-specific guidance. 
  • DAPRA: DAPRA has not issued guidance regarding this topic. Please contact the program officer if an extension to a reporting deadline is needed.
  • USAMRAA: The USAMRAA will allow grantees to delay submission of progress reports up to three months beyond the normal due date.  For any other deliverables related to research awards, please contact the grants manager and/or program manager for award-specific guidance. 
  • ONR: Technical reports for ONR grants are due on June 15, 2020. ONR still expects these reports by June 15, 2020 but will not consider reports submitted after this date late. The ONR grants portal for investigators closes after August 15, 2020,  reports must be submitted by that date until further notice.
  • Donation of Personal Protection Equipment (PPE): The donation of PPE and other lab supplies to support efforts related to COVID-19 requires prior approval from the DoD agency.  Please contact your Sponsored Projects Team to request 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. 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. 
  • Non-refundable Travel Expenses: Non-refundable travel costs for cancelled events may be charged to the award if the event, travel, or other activity was needed to perform the originally-proposed work. Please do not assume supplemental funds will be made available to cover a shortage of funds.
  • Costs of pausing and restarting research activities: Costs of pausing and subsequently restarting research activities may be charged to the DoD award if the costs can be clearly attributed to the specific award. Documentation will be key with these expenses as they need to be inarguably needed because of COVID-19. If the charging of these costs to the award results in a shortage of funds needed to carry out the remainder of the project, do not assume DoD will award supplemental funding. Please contact the DoD program officer 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 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