Notice Number: NOT-HS-20-010
Release Date: April 6, 2020
RFA-HS-20-003 - Novel, High-Impact Studies Evaluating Health System and Healthcare Professional Responsiveness to COVID-19 (R01)
AGENCY FOR HEALTHCARE RESEARCH AND QUALITY (AHRQ)
The purpose of this Notice is to alert the AHRQ grantee community of administrative flexibilities that will apply to AHRQ applicants and recipients. The Office of Management and Budget (OMB), in memorandum M-20-17, dated March 19, 2020, titled “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations” has identified several short-term administrative flexibilities that Federal awarding agencies may implement to assist recipients with managing administrative, financial management and audit requirements under the Uniform Guidance “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” – which are implemented in HHS regulation at 45 CFR Part 75,– without compromising Federal financial assistance accountability requirements.
The Agency for Healthcare Research and Quality (AHRQ) recognizes the significant effects that the HHS-declared COVID-19 national emergency is having on AHRQ-funded research and human subject studies, and we want to assure our grantee recipient community that AHRQ will be doing our part to help you continue your research. First and foremost, we are concerned about the safety and welfare of human subject participants and research staff that interact with study participants. Institutions should take all steps necessary to ensure the safety of all human participants and research staff involved in AHRQ-funded research and human subjects studies. Principal Investigators (PIs) should work with their institution’s office of sponsored programs regarding any changes that may need to be made to a study’s design and/or timeline. If it is determined that there is a request that requires AHRQ prior approval or review, an authorized institutional official should submit a formal request to the Grants Management Specialist named on the most recent Notice of Award (NOA).
The following flexibilities are applicable to AHRQ applicants and recipients impacted by COVID-19 due to loss of operations. At this time, these flexibilities are time-limited and will expire June 19, 2020, or sooner should OMB withdraw the authority. If OMB extends the flexibilities under M-20-17 beyond June 19, 2020, AHRQ will re-evaluate its implementation.
Affected entities are those that have been closed, or business activities have been hindered, due to COVID-19 precautionary measures and/or illnesses. Entities that are affected will be asked to provide documentation to AHRQ describing the effects, and how long their facility and AHRQ related research or training was and/or will be affected.
1. Flexibility with SAM registration. (2 CFR § 200.205)
AHRQ is relaxing the requirement for active System for Award Management (SAM) registration at time of APPLICATION in order to expeditiously issue funding.
At the time of award, the requirements of 2 CFR § 200.205, Federal awarding agency review of risk posed by applicants, continue to apply, therefore an active SAM registration is required at the time of award. Current registrants in SAM with active registrations expiring before May 16, 2020 will be afforded a one-time extension of 60 days.
2. Flexibility with application deadlines. (2 CFR § 200.202)
AHRQ will be highly accommodating of late applications submitted through May 1, 2020. We anticipate, but cannot guarantee, that all late applications submitted by that date will be reviewed in the council round to which they were submitted. As much as AHRQ would like to extend flexibility further, this rapidly evolving situation also creates multiple challenges for conducting peer review, and the timeline for getting review outcomes completed (so that funding can occur) can only be delayed so long. Therefore, applicants should assume that late applications submitted after May 1 may experience delay in peer review.
3. Waiver for Notice of Funding Opportunities Publication. (2 CFR § 200.203)
As deemed necessary, AHRQ will use the flexibility afforded it to publish emergency Notice of Funding Opportunities for competitive grants and/or cooperative agreements for less than thirty (30) days.
4. No-cost extensions on expiring awards. (2 CFR § 200.308)
AHRQ recipients are to follow standard procedures for either notifying AHRQ of one-time no-cost extensions of up to 12 months for grants that are awarded under expanded authorities, or requesting prior approval for no-cost extensions of grants that are not awarded under expanded authorities. The most recent Notice of Award will indicate whether or not a particular award is under expanded authorities. Please refer to AHRQ’s FAQs for details: https://info.ahrq.gov/search?q=&category=8.
5. Abbreviated non-competitive continuation requests. (2 CFR § 200.308)
AHRQ recipients are to follow standard procedures and due dates for submitting complete Research Performance Progress Reports (RPPRs) to request non-competing continuation support. At this point in time, it is AHRQ’s understanding that all FY2020 Appropriated funds will need to be awarded before September 30, 2020, therefore delays in receipt of RPPRs could delay processing and jeopardize recipient receipt of funding in FY2020. However, AHRQ will consider requests for reasonable extensions of RPPR due dates on a case-by-case basis; please contact the Grants Management Specialist named on the most recent NOA.
6. Allowability of salaries and other project activities. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405)
AHRQ will allow recipients to continue to charge salaries and benefits to currently active AHRQ awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal.
AHRQ will allow other costs to be charged to Federal awards necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project.
AHRQ will evaluate the grantee's ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances, based on subsequent progress reports and other communications with the grantee.
AHRQ requires recipients to maintain appropriate records and cost documentation as required by 2 CFR § 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.
7. Allowability of Costs not Normally Chargeable to Awards. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405)
AHRQ will allow recipients who incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to the public health emergency, to charge these costs to their award without regard to 2 CFR § 200.403, Factors affecting allowability of costs, 2 CFR § 200.404, Reasonable costs, and 2 CFR § 200.405, Allocable costs.
AHRQ will allow recipients to charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant.
Note: It is expected that recipients will attempt to have cancellation fees waived under any flexibilities vendors are allowing due to COVID-19.
AHRQ advises recipients that they should not assume 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. AHRQ requires recipients to maintain appropriate records and cost documentation as required by 2 CFR § 200.302 -Financial management and 2 CFR § 200.333 Retention requirement of records, to substantiate the charging of any cancellation or other fees related to interruption of operations or services.
8. Prior approval requirement waivers. (2 CPR § 200.407)
AHRQ is allowing pre-award costs to be incurred from January 20, 2020, through the COVID-19 public health emergency period and prior to the date of a federal award for all applicants and recipients that have been impacted by COVID-19 due to loss of operations. All costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award, unless otherwise specified in this Notice.
9. Exemption of certain procurement requirements. (2 CPR§ 200.319(b), 2 CPR§ 200.321)
AHRQ waives the procurement requirements contained in 2 CPR§ 200.319(b) regarding geographical preferences and 2 CPR§ 200.321 regarding contracting small and minority businesses, women's business enterprises, and labor surplus area firms, for all applicants and recipients that have been impacted by COVID-19 due to loss of operations.
10. Extension of financial, performance, and other reporting. (2 CPR§ 200.327, 2 CPR§ 200.328)
AHRQ will allow grantees to delay submission of financial, performance and other reports up to three (3) months beyond the normal due date. Grantees will be allowed to continue to draw down Federal funds without the timely submission of these reports. However, these reports must be submitted at the end of the postponed period.
AHRQ does not waive the requirement for recipients to notify the agency of problems, delays or adverse conditions related to COVID-19 on a grant by grant basis (200 CPR 200.328(d)(l).
NOTE: This excludes annual RPPR submissions; please see item 5 above (“Abbreviated non-competitive continuation requests”).
11. Extension of currently approved indirect cost rates. (2 CPR§ 200.414 (c))
HHS may allow grantees to continue to use the currently approved indirect cost rates (i.e., predetermined, fixed, or provisional rates) to recover their indirect costs on Federal awards. The cognizant agency for indirect costs may approve grantee requests for an extension on the use of the current rates for one additional year without submission of an indirect cost proposal. The cognizant agency for indirect costs may also approve grantee requests for an extension of the indirect cost rate proposal submission to finalize the current rates and establish future rates. AHRQ recipients who wish to avail themselves of either of these options are to contact the HHS Program Support Center, Financial Management, Cost Allocation Services at https://rates.psc.gov/.
12. Extension of closeout. (2 CPR§ 200.343)
AHRQ will allow the grantee to delay submission of any pending financial, performance and other reports required by the terms of the award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the grantee to the AHRQ Grants Management Specialist named on the most recent NOA. This delay in submitting closeout reports may not exceed one year after the award expires.
13. Extension of Single Audit submission. (2 CFR § 200.512)
AHRQ, in its capacity as cognizant or oversight agency for audit, will allow recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of this memorandum that have fiscal year-ends through June 30, 2020, to delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501 -Audit Requirements, to six (6) months beyond the normal due date. No further action by AHRQ is required to enact this extension. This extension does not require individual recipients and subrecipients to seek approval for the extension by the cognizant or oversight agency for audit; however, recipients and subrecipients must maintain documentation of the reason for the delayed filing. Recipients and subrecipients taking advantage of this extension would still qualify as a "low-risk auditee" under the criteria of 2 CFR § 200.520 (a)-Criteria for a low-risk auditee.
As the COVID-19 national emergency continues, recipients may identify additional cost-related flexibilities that are needed. AHRQ will consider such requests on a case-by-case basis. Principal Investigators need to work with their institution’s office of sponsored programs regarding any cost-related flexibilities that may be needed. If it is determined that there is a request that requires AHRQ prior approval or review, an authorized institutional official should submit a formal request, including an explanation of the effect of COVID-19 on the project and the flexibility being requested, to the Grants Management Specialist named on the most recent Notice of Award (NOA). AHRQ will consider such requests in line with the Federal cost principles, AHRQ policy, and need to support the project.
Please direct all inquiries to:
AHRQ Division of Grants Management