May 11, 2020<\/p>\n
Memo to Principal Investigators and Research Administrators,<\/p>\n
The purpose of this memo is to update researchers and administrators on requirements for awards that have been impacted by the COVID-19 emergency. The Office of Management & Budget (OMB) released guidance<\/a> on March 19th<\/sup> allowing a number of flexibilities for the research community including the allocation of idle time to research awards. OMB will be reassessing their guidance to federal agencies by June 17th. The current Boston University policy allows charges on federal awards for idle time through June 1st.\u00a0\u00a0 Under federal guidance and BU policy, we have a responsibility to maintain adequate documentation of research\/programmatic progress, personnel effort, and other project costs or delays impacted by the pandemic. This information will be needed to support your research program for several reasons:<\/p>\n Documentation <\/strong><\/p>\n Idle time (sometimes referred to as non-productive time) refers to the time an employee would have spent on their research had COVID-19 not caused disruptions to campus operations. While idle time has been allowable on most federal awards since the release of OMB\u2019s guidance it was only recently that documentation requirements related to this time were made available. To assist with the documentation of idle time, Post Award Financial Operations (PAFO) will be distributing worksheets via SharePoint to Department Administrators and Researchers to indicate where idle time should be noted due to disruptions of COVID-19. These worksheets will show the percentage allocation of salary for employees on grants for the prior periods (March and April) as recorded in our systems.\u00a0\u00a0 Further instructions will follow under separate cover with the SharePoint site link.<\/p>\n Summer Salary <\/strong><\/p>\n Our Awarding Agencies have yet to release firm guidance regarding summer salary. Based on existing guidance and through discussions with our peer institutions we do not believe that awarding agencies will reimburse compensation for 9-month faculty researchers whose research is idle for periods during the summer due to COVID-19 disruptions. We expect that awarding agencies will continue to reimburse compensation for researchers who are working remotely and those that can continue research on campus.<\/p>\n New Awards <\/strong><\/p>\n The OMB guidance released on March 19 states that \u201cAwarding agencies may allow recipients to continue to charge salaries and benefits to currently active<\/strong> Federal awards \u2026<\/em>\u201d therefore idle time will likely be unallowable expenses on new<\/strong> awards. For example, NIH FAQs<\/a> explicitly state \u201cRecipients may not initiate charges for salaries and benefits on new awards where the work has not yet started\u201d. <\/em>This decision may vary across sponsors.<\/p>\n If you receive a new award and have questions about how to proceed, please reach out to your SP RA to discuss.\u00a0 We are currently processing all new awards.\u00a0\u00a0 If your ability to carry out the work is severely impacted we may let the sponsor know you cannot begin the work now, and share your plan on resumption.<\/p>\n Communications with Sponsors<\/strong><\/p>\n During this time, any communications to your Program Officer should be shared with SP.\u00a0\u00a0 If you are proposing a supplement, change in scope or budget, or prior approval requests, they should first be reviewed by your Sponsored Programs Research Administrator.\u00a0\u00a0 Generally, those requests are authorized by SP and shared with your Grants Management Official at the Sponsor by SP. While sponsors have documented flexibilities on requirements for projects impacted by the COVID crisis, please remember prior approval requirements still exist for active awards and awards with effort requirements (such as NIH Career Development awards). Also, if your research is funded under a federal contract, the flexibilities under the OMB guidance<\/a> on March 19th<\/sup> may not apply.\u00a0 You are also required to inform your funder about any impacts (programmatic or financial) on the contracted work.\u00a0 Please reach out to your SP RA should you have any questions.<\/p>\n If you receive any communications from your Sponsor or Program Officer, please be sure to share it with Sponsored Programs (ospera@bu.edu<\/a>).<\/p>\n We continue to regularly update the Research COVID website<\/a>.\u00a0\u00a0 We recommend that you check this resource weekly for further guidance.\u00a0\u00a0 Please reach out to us with your questions<\/p>\n <\/p>\n Sincerely,<\/p>\n Diane Baldwin \u2013 Associate Vice President, Sponsored Programs (dbaldwin@bu.edu<\/a>)<\/p>\n Renna Lilly \u2013 Director, Pre Award Services, Sponsored Programs (rolilly@bu.edu<\/a>)<\/p>\n Andrew Soares White \u2013 Vice President, Financial Operations (asoares@bu.edu<\/a>)<\/p>\n\n