Allowable Costs and Effort

In accordance with institutional policy, all Duke faculty, staff, and students will continue to stay in a paid work (or academic/training status for students) status regardless of physical location or schedule and should record their normal hours. For individuals engaged in research, effort should be recorded at the current or planned levels. Pay distribution should reflect the effort recorded. The NIH, DoD, and NSF have issued statements allowing for the continued charging of salaries, regardless of the work schedule. We expect that other sponsors/agencies will release similar guidance, but as they have yet to issue statements, individuals and projects with other sponsored funding should be aware of the critical importance of documenting effort expended during this time; this includes industry and foundation sources.

Individuals should make every effort during this time to maintain documentation of effort expended in support of the grant remotely versus effort booked without the ability to perform work on the grant, in the event that other sponsors/agencies do not allow for the charging of salaries when effort in support of the grant is not possible.

Note:

• If the individual is working remotely and contributing to the project, then salary can be charged to the grant.
• If an individual cannot contribute to their current project but can contribute to another sponsored project or institutional activity (including support of the clinical mission), the salary must be moved to that funding source.
• If an individual cannot perform job functions related to any university or sponsored project because of requirements to work remotely, their salary is allowable in accordance with university and sponsor regulations.

While we await further guidance, projects should charge salaries and fringes to all sponsors where the sponsor has yet to release guidance. They may need to be removed based on future sponsor guidance, therefore PIs and GMs should complete the related form Sponsored Projects Worksheet: Tracking COVID-19 Related Idle Project Effort and ensure that it is retained in the department.

In general, yes, provided the project personnel remain engaged on the project. Current sponsor prior approval requirements regarding disengagement and effort reductions remain in effect. This requires supervisor and PI approval to ensure allowability and programmatic support of science.

Yes. Pursuant to Duke’s benefits, sick leave and other paid absences that are permitted under University policy and treated consistently may be charged to the grant.

These types of expenses are considered administrative costs (indirect costs), and generally are not appropriate as a direct cost unless specifically approved by the sponsor. You may wish to talk with your supervisor about your needs in order to be set up to work remotely.

Regardless of funding organization, the individual's first priority should be to work with the airline/hotel, as many are waiving change fees or are offering full refunds for trips that you wish to change. Duke University Employee Travel & Reimbursement (ET&R) has provided updates for miscellaneous business practices during the response to COVID-19. Per these updates and underlying University guidance, travelers who are assessed change/cancellation fees are able to submit these for reimbursement. The NIH provided a notice (NOT-OD-20-03), the NSF has released guidance regarding the implementation of OMB authority, and the DOE issued a memo allowing for the direct charging of these costs to grants. We think it is likely that sponsors will allow reasonable cancellation costs as direct charges to grants and contracts in this set of circumstances. In order to be allowable, it is reasonable to assume that the traveler has requested and been denied a refund, and that documentation of such a request is retained in the department. We also ask that you keep track of such transactions to allow for corrections in the event that funding agencies issue guidance that is in contradiction to this practice.

Duke University has suspended all university-funded non-essential international and domestic travel. Requests for exceptions should be made to your supervisor or dean. Contact the meeting organizer to see if they have made contingency plans, such as cancellation, rescheduling or virtual participation is available. If you are the host, we recommend developing contingency plans in accordance with University guidance, travel policies and general cost principles described in University policies and procedures.

Until we received different guidance from federal sponsors, the general answer is that this should be funded via institutional funds (i.e., should not be placed on a grant) as it is not clear as to whether this credit will be used at some future date to benefit the initial grant in question, or something else.

If a traveler has charged (e.g., through a travel advance) an airline ticket or other travel cost to a sponsored project, and then that trip is later canceled, the refund must accrue to the sponsored project.

If the PI (organizer) should confer with his or her program officer and grants management specialist to decide whether to cancel the meeting, postpone the meeting, or convert the meeting to an on-line format. These considerations should take into account any declared states of emergency for the planned location. 

This request for input is consistent with 2 CFR 200.407 which says in part: “the non-Federal entity may seek the prior written approval of … the Federal awarding agency in advance of the incurrence of special or unusual costs.”  Note that any communication to the sponsor must be coordinated through the Office of Research Administration (ORA - Medicine/Nursing) or the Office of Research Support (ORS - Campus).      If the request is made verbally, written documentation of the decision should follow (an email from the sponsor to the PI and ORA/ORS should be sufficient).      At many federal agencies, the program officer cannot independently make this type of decision, and grants office concurrence is required.  PIs should follow the requirements for their specific sponsor.  

Duke University has cancelled, postponed or virtualized all university-sponsored events expecting over 50 people in attendance through May 7, 2020, and has urged the transition of all in-person meetings to virtual for the time being. 

Organizers may wish to make a firm decision about rescheduling or cancelling a meeting early enough to enable their participants to take advantage of discounts offered by airlines or hotels related to COVID-19 changes or early cancellation (particularly for hotels). In addition, a decision by the organizer to cancel the conference may assist some participants in convincing their institution to pay their cancellation costs.  

If approved by the sponsor, once cancelled, the non-refundable costs for the venue would be an allowable charge to the project (if the project was scheduled to incur those costs in the first place). In general, the costs for participants should follow the funding stream intended to pay for their attendance; if the conference grant was reimbursing all or part of the participation costs for all attendees, it may be appropriate to also charge some or all of their cancellation fees. If participants were covering their own attendance costs (from sponsored or non-sponsored sources), then then the cancellation costs should follow the sponsor funding their participation or the participant’s employer.

Generally, no it is not allowable, although we are still waiting for federal guidance. It should be noted that traveler’s insurance may be prudent, but should be charged to institutional funds (but not to a grant) until we get additional federal input.

Many federal sponsors have released guidance allowing projects to charge cancellation fees from conferences and travel to grant funds. This includes the NIH, NSF and DOD. Projects should take care to maintain documentation of the original charges and fees accrued due to cancellation.

The federal agencies have not yet issued guidance on this topic. However, because 2 CFR 200.430 requires consistency across all fund sources but allows variation depending on employment terms for different classes of employees and different appointment terms, we currently believe it likely that any salary allowed under the University emergency policy will be allowed regardless of whether an employee is paid on a sponsored or non-sponsored fund source (or both.)  Watch for updated guidance as it becomes available.

If a grant-funded employee stays home due to a school or facility closure for child or elder care needs, the employee’s salary would be charged in accordance with Duke policy.  See Duke’s Keep Working FAQs for more information.

In most cases, grantees should be able to continue work until their period of performance and funding is exhausted. If prior approvals are required, the PI (with applicable institutional coordination and countersignature) should continue to submit their request to the funding agency using the normal mechanism for that agency (email or online system). In the event approval is not forthcoming within the time period for action allowed by the agency (typically 30 days), the PI will need to make a decision about whether to proceed with the action for which approval was requested, understanding that any costs associated with that change may need to be absorbed by the PI if approval is not subsequently granted. For cooperative agreements and contracts that require agreement officer or contracting officer approval, the risk is likely to be higher.

Federal agencies have released guidance providing differing levels of administrative flexibility for ongoing research projects. Projects should consult the Agency-Specific Updates for information relevant to their funding organizations. In general, if the impacts from COVID-19 will result in a change in budget or scope of the project, the project should communicate such issues to their program officer or grants management specialist by following the COVID-19 Notice to Sponsors process.

As a reminder, recipients are required to (1) inform their program officer and grants officer if the need arises for additional Federal funds to complete the project; and (2) federal agency notification is required as soon as “problems, delays, or adverse conditions which will materially impact the ability to meet the objective of the Federal award” is known. In the latter case, the notification must include a statement of the action taken or contemplated and any assistance needed to resolve the situation. It is possible that there will not be an answer yet on what is needed to resolve the situation; in that case, recipients should indicate that they will report back when more is known.  If you have this situation, contact the Office of Research Administration (ORA – Medicine/Nursing) or the Office of Research Support (ORS – Campus) to find out how to report it to an agency (email or via the agency’s online system). ORA/ORS must countersign such notifications/requests.