College Grants & Sponsored Programs
On March 19, the US Office of Management and Budget released official guidance (see M-20-17) for recipients of federal assistance. Per Appendix A, Item 6, funding agencies may allow grant recipients to continue to charge salaries/wages and benefits to active awards, consistent with the recipient's (Union's) policy of paying salaries from all funding sources, federal and non-federal. Union College’s temporary policy on pay continuity for grant-funded personnel has changed effective June 18, 2020 in response to changes in federal guidance. The revised federal guidance in OMB M-20-26 adds a significant restriction to the previous interim policy on the use of grant funds during loss of operations.
Per National Science Foundation (NSF) Implementation of OMB Memorandum M-20-26, issued June 25, 2020, “Due to the limited funding resources under each NSF award necessary to achieve its specific project, as specified in M-20-26, recipients must exhaust other available funding sources to sustain its workforce and implement necessary steps to save overall operational costs (such as rent renegotiations) during this pandemic period in order to preserve Federal funds for the ramp-up effort. Recipients should retain documentation of their efforts to exhaust other funding sources and reduce overall operational costs.”
In the event of a COVID-19 college shut-down, Principal Investigators must follow all relevant policies and procedures, including those of Union College, and apply those practices consistently. PIs must determine availability of discretionary, departmental, and college resources (e.g., Faculty Research & Travel) prior to expending grant funds, and must retain records, to substantiate the availability of institutional resources or charging of any salaries and other project activities costs related to interruption of operations or services. PIs are asked to consult with the Office of College Grants & Sponsored Programs in the event of a college shut-down or other impacts on grant award activities.