COVID-19 Grantee Frequently Asked Questions

HRSA recommends grant recipients first consult their organizational policies and procedures for suitability to work from home, potential acceptable grant duties while working from home, and processes for reimbursements. Allowable costs awarded under a HRSA grant, would be permissible for reimbursement to an employee approved to work on grant duties at home (due to COVID-19; Ref: 2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405) in accordance with; the Uniform Administrative Requirements, Federal cost principles, audit requirements for HHS awards (45 CFR Part 75) and consistent with the recipients organizational policies and procedures.

Re-budgeting into an approved budget category up to 25% of the total grant funds are allowable following standard grant policy. Revisions to budgets that exceed 25%; require a Prior Approval request. We anticipate these costs/activities will be short-term, for the duration of the COVID-19 and not a long term situation.

Recipients should not assume additional funds will be available should the charging of the unexpected expenses result in a shortage of funds to carryout approved project activities. Award recipients must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 - Financial management.

Cost Principles (45 CFR Part 75, Subpart E) must be used in determining allowable costs that may be charged to a HRSA award. Costs must be necessary and reasonable to carry out grant approved project activities, allocable to the funded grant project, and allowable under the Cost Principles, or otherwise authorized by the grant program statute. The treatment of costs must be consistent with recipient or sub-recipient policies and procedures that apply uniformly to both federally-financed and other non-federally funded activities.

Costs that are not described in the funding opportunity or based in the referenced grant program statute are not approvable under a HRSA grant.  Items that would not have been approved prior to COVID-19 are not allowed under the OMB M-20-17 flexibilities.

The Department of Labor has posted information related to COVID-19 effects on wages, work hours, and leave categories.

Yes. Per guidance issued by Office of Management and Budget (OMB) M-20-26, HRSA recipients may continue to charge salaries and benefits to currently active awards consistent with their organization's policy of paying salaries under unexpected or extraordinary circumstances from all funding sources, federal and non-federal through September 30, 2020.

During the COVID-19 emergency, internal controls over time and effort documentation and reporting under 45 CFR 75.430 may be adjusted for staff unable to report for work; however, recipients must document that that they are following their organizational policy for charging salaries during unexpected and extraordinary circumstances and they must be able to substantiate federal funds expended in accordance with HRSA guidance (this FAQ) as adopted and permitted by all applicable OMB memos.

Recipients must maintain appropriate records and cost documentation as required by 45 CFR § 75.302 - Financial management and standards for financial management systems and 45 CFR § 75.361 - Retention requirement for records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services.

With the rescission of OMB Memo M-20-17 (PDF - 5.4 MB), HRSA has accordingly returned to standard prior approval requirements. The Grants Management Specialist assigned on your Notice of Award can provide specific information if you need additional assistance.

With the rescission of OMB Memo M-20-17, HRSA has accordingly returned to standard procurement requirements.

If your organization is unable to submit an application by the published NOFO deadline due to justified circumstances (such as impacts from COVID-19), you may request an extension. As referenced in the SF-424 Application Guide (PDF - 688 KB) on pages 14-15 and 48, HRSA's Division of Grants Policy (DGP) in the Office of Federal Assistance Management is the only office authorized to grant extensions. You must contact the DGP via email at DGPWaivers@hrsa.gov and provide a brief explanation and your earliest estimated date of submission.

Your email must include:

• HRSA funding opportunity number;
• name, address, and telephone number of the organization;
• organization's DUNS number;
• and name and telephone number of the Project Director.

Please contact DGP as soon as possible if you anticipate issues completing your application on time and need to request an extension. While HRSA cannot guarantee that every extension request will be approved for the amount of time requested, every effort will be made by HRSA staff to provide administrative relief to applicants impacted by COVID-19. Applicants are also reminded to select "Subscribe" and provide your email address in the Grants.gov workspace for each NOFO you are reviewing or preparing in order to receive notifications including modifications (e.g., a new application due date), clarifications, and/or re-publication of the NOFO on Grants.gov before its closing date.

As outlined in 45 CFR 75.203, HHS awarding agencies adhere to a standard of providing 60 days for applicants to apply for competitive NOFOs, but may not post NOFOs for less than 30 days without additional approval from HHS.

HRSA consistently publishes NOFOs for 60 days or more to provide applicants with the time needed to submit quality applications.

Applicants may search for applicable funding opportunities at Grants.gov.

HRSA is committed to assisting our recipients during these difficult times. To that extent, if you are unable to submit your non-competitive continuation (NCCs) report by the posted due date, please contact your grants management specialist via email or phone. 

Initial contact will be used to determine next steps, which may include, permitting a deadline extension, allowing for a one-time limited non-competitive continuation report, or other determinations as deemed appropriate.  Please note, non-competitive continuation reports vary by program so it is important to contact your HRSA grant official for specific guidance.  All requests will be handled on a case by case basis, depending on recipient circumstances.

Extension requests can be made through HRSA's Electronic Handbooks. Contact your Grants Management Specialist with any additional questions.

Request an extension through HRSA’s Electronic Handbook - how to request an extension. Contact your Grants Management Specialist with questions.

Request an extension through HRSA’s Electronic Handbooks - how to request an extension. Contact your Grants Management Specialist with any questions.

Yes. Per guidance issued by the Office of Management and Budget in Memoranda M-20-26. OMB Memo M-20-26, issued on June 18, 2020, rescinded many of the previous audit extensions that had been provided by OMB in OMB Memo M-20-11 and M-20-17. The only remaining extensions permitted relate to fiscal year-ends ending December 31, 2019, and prior. The following summarizes the extensions permitted:

Six-month extensions (Normal due dates between March 30, 2020, and June 30, 2020, based on fiscal year ends between June 30, 2019, and Sept. 30, 2019) - HRSA recipients that are affected by the loss of operational capacity due to COVID-19, have not filed their audit by March 19, 2020, and have a normal due date from March 30, 2020, through June 30, 2020, may delay their Single Audit submissions up to six months beyond the normal due date.

Three-month extensions (Normal due dates between July 31, 2020, and Sept. 30, 2020, based on fiscal year ends between Oct. 1, 2019, and Dec. 31, 2019) – HRSA recipients that are affected by the loss of operational capacity due to COVID-19, have not filed their audit by March 19, 2020, and have a normal due date from July 31, 2020, through Sept. 30, 2020, may delay their Single Audit submissions up to three months beyond the normal due date.

If you believe you were adversely affected by COVID-19 and you choose to delay your single audit submission, you are not required to seek prior approval; however, you should maintain documentation of the reason for the delayed filing.

If you have questions about your ability to obtain extensions or if you want to inform HRSA you will be taking advantage of the flexibilities, email HRSA's Division of Financial Integrity.

The flexibility provided by OMB Memo M-20-17, to relax the requirement for active System for Award Management (SAM) registration at the time of application, has expired.  All applicants should have and maintain an active SAM registration in order to apply for federal awards. 

If you are experiencing technical difficulties at Grants.gov, please contact the Grants.gov Applicant Support Help Desk at 1-800-518-4726.

With the rescission OMB Memo M-20-17, the requirement to have an active System for Award Management (SAM) registration requirement at the time of application is in effect for recipients as well as sub-recipients.

HRSA recipients may charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant; for the period OMB M-20-17 was in effect: 3/19/2020 – 6/16/2020.

Recipients should not assume that additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel.

Recipients must maintain appropriate records and cost documentation as required by 45 CFR § 75.302 - Financial management and standards for financial management systems and 45 CFR § 75.361 - Retention requirement for records to substantiate the charging of any cancellation or other fees related to interruption of operations or services.

Recipients may contact: HHS PSC Cost Allocation Services. Commercial recipients may contact: NIH Division of Financial Advisory Services Indirect-Cost Branch.

This change applies to all Health and Human Services (HHS) grants and cooperative agreements.