COVID-19 Grantee Frequently Asked Questions

Allowable costs incurred by recipient grants staff performing grant duties while teleworking would be permissible (due to COVID-19; Ref: 2 CFR § 200.403-.405) in accordance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards (45 CFR Part 75) and consistent with the recipients organizational policies and procedures.

For telecommunications, video surveillance services and/or equipment costs please see HRSA Standard Terms #15 Prohibition on certain telecommunications and video surveillance services or equipment.

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

Recipients must document that they are following their organizational policy for charging salaries during unexpected and extraordinary circumstances and recipients must be able to substantiate federal funds expended in accordance with HRSA guidance.

As a reminder, recipients must maintain appropriate records and cost documentation as required by 45 CFR § 75.302- Financial management and standard for financial management systems and § 75.361 Retention requirements for records (Corresponding 2 CFR references are: § 200.302 -Financial management and 2 CFR § 200.333 - Retention requirement of records) to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services.

Allowable and necessary pre-award costs for American Rescue Plan Act of 2021 (ARP) purposes that are incurred: (i) from March 15, 2021 through the Public Health Emergency Period; and (ii) prior to the effective date of a Federal award may be acceptable per 45 CFR § 75.458- Pre-Award costs (Corresponding 2 CFR § 200.458). Recipients are reminded all costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award. Appropriate records and cost documentation (45 CFR § 75.302- Financial management and standard for financial management systems and § 75.361 Retention requirements for records) (Corresponding 2 CFR references are: § 200.302- Financial management and 2 CFR § 200.333- Retention requirement of records) to substantiate any pre-award cost is required.

The Grants Management Specialist on your Notice of Award can provide information regarding waiving specific prior approval requirements as necessary to effectively address the COVID response. All costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award.

OMB M-21-20 (PDF - 372 KB) provides flexibility to waive the procurement requirements regarding contracting small and minority businesses, women's business enterprises, and labor surplus area firms may be waived. Recipients are reminded of 45 CFR § 75.327 - General Procurement Standards and § 75.328 - Competition and the requirement to maintain appropriate records regarding the circumstances for the waiver and documentation to support the charges against the Federal awards. (45 CFR § 75.302 and § 75.361).

If your organization is unable to submit an application by the published NOFO deadline due to justified circumstances you may request an extension. As referenced in the SF-424 Application Guide (PDF - 700 KB) on pages 14-15 and 48, HRSA's Division of Grants Policy and Planning (DGPP) in the Office of Federal Assistance Management is the only office authorized to grant extensions. You must contact the DGPP via email at ApplicationWaivers@hrsa.gov and provide a brief explanation and your earliest estimated date of submission. Request for extensions will be considered on a case-by-case basis.

Your email must include:

• HRSA funding opportunity number;
• name, address, and telephone number of the organization;
• organization's DUNS number (soon to be Unique Entity Identifier (UEI) number); and
• name and telephone number of the Project Director.

Please contact DGPP as soon as possible if you anticipate issues completing your application on time and need to request an extension. 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. Only in a rare emergency does HRSA post a NOFO for less than 60 or 30 days.

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

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.

Please note, non-competitive continuation reports vary by program, so it is important to contact your HRSA Grants Management Specialist for specific guidance. All requests will be handled on a case-by-case basis, depending on recipient circumstances and grant program regulations.

As of October 2021, Federal Financial Reports (FFR-SF-425) are submitted directly in the Payment Management System (PMS) through the HHS Program Support Center (PSC). Due to this change, recipients are unable to request extensions for FFR submissions via EHBs. If you are unable to submit your FFR by the required deadline, contact via email the Grants Management Specialist (GMS) named on your most recent Notice of Award for assistance in requesting an extension. The GMS will also be able to address concerns regarding other required reports.

Request an extension through HRSA’s Electronic Handbook - how to request an extension. If you are unable to submit your Federal Financial Report (FFR-SF-425) by the required deadline, contact the Grants Management Specialist named on your most recent Notice of award for additional assistance.

Based on the March 19, 2021 OMB Memorandum M-21-20 (PDF - 372 KB) (Appendix 3, § IX), recipients and subrecipients that have not filed their Single Audits with the Federal Audit Clearinghouse, as of the date of the memorandum, that have fiscal-year ends through June 30, 2021, may delay the completion and submission of their Single Audits to six months beyond the normal due dates.

The six-month extension provided by the OMB Memorandum applies to recipients and subrecipients of Federal financial assistance awards that were affected by the pandemic, not just those that received Federal funding related to COVID-19.

If you choose to delay your Single Audit submissions, you are not required seek prior approval. However, you should maintain documentation of the reason for the delayed filing.

If you have questions about your ability to obtain the extension or want to inform HRSA you will be taking advantage of this flexibility, please email HRSA's Division of Financial Integrity.

Yes. OMB M-21-20 (PDF - 372 KB) provides flexibility for the Management requirement related to Physical Inventories. Recipients may exercise an extension (up to 12 months) for the biennial physical inventory of equipment purchased under a Federal award (as required by 45 CFR § 75.320 Equipment (d)(2))(corresponding 2 CFR §200.313 (d)(2)). Recipients are reminded to maintain appropriate records and cost documentation to document compliance with the management requirements. (45 CFR § 75.302 and § 75.361).