Stanford recently announced a commitment to continue to pay salary and benefits to full-time and part-time benefits eligible employees at the present time, regardless of funding source or without respect to the number of hours worked. Questions have arisen as to whether or not these charges are allowable on sponsored projects.
The Office of Management and Budget (OMB) issued notifications to all federal agencies on March 9 and 19, 2020 providing Administrative Relief related to COVID-19:
Awarding agencies may allow recipients to continue to charge salaries and benefits to currently active Federal awards consistent with the recipient organization’s policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Agencies may allow other costs to be charged to Federal awards, including those necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. Federal agencies may also evaluate the recipient’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 recipient.
As a result, each agency has the option to exercise this flexibility and these charges may be fully allowable on federally sponsored awards, since they are in line with University policy. It is important to note that at this time, only a few agencies (e.g. NIH and NSF) have offered specific approval, but we are hopeful other agencies will agree to do so as well. Agency-specific guidance received from major sponsors can be found on the ORA COVID-19 resource page. In addition, any questions or information needed on the allowability of continued salary support from either federal or non-federal sponsored projects should be directed to your Institutional Official in OSR, RMG or ICO. If any of your sponsored project activities (federal or non-federal) are hindered due to COVID-19 precautionary measures and/or illnesses and sponsor accommodations are needed, please complete the COVID-19 Sponsor Notification and Request Form and submit it through the SeRA system via a Central Office Request (select Request Type “COVID-19 Sponsor Notification/Request”). Your Institutional Official will work with the sponsor to notify and/or request approval as needed. Instructions for submission can be found on the ORA COVID-19 resource page.