March 30, 2020

Application of OMB Memo M-20-17 to NIDILRR Grants

In recent weeks NIDILRR has been receiving regular updates from our grantees across the 

country – about the ways that the COVID-19 pandemic is impacting their communities, 

organizations, and their NIDILRR-funded research and related activities. NIDILRR is prioritizing 

the health and safety of our grantees and the people with disabilities who participate in 

NIDILRR-funded research efforts. 

The purpose of this correspondence is to implement the flexibilities outlined in the Office of 

Management and Budget’s Memo M-20-17 among grantees in the NIDILRR community. OMB’s 

memo describes “Administrative Relief for Recipients and Applicants Impacted by the Novel 

Coronavirus (COVID-19) due to Loss of Operations.” Below you will find brief guidance 

regarding NIDILRR’s implementation of the 13 points contained in OMB memo M-20-17. 

Please note that these administrative relief flexibilities are intended to be time limited. OMB 

plans to reassess their applicability within 90 days and NIDILRR will update our guidance, as 

needed, at that time. 

NIDILRR grantees must maintain appropriate records and documentation necessary to support 

charges to their awards under these flexibilities. 

1. Flexibility with SAM registration (2 CFR § 200.205)

In an effort to reduce the administrative burden for applicants, the General Services 

Administration (GSA) will automatically issue a 60-day extension for entities with SAM 

expiration dates between March 19, 2020 and May 17, 2020. This flexibility applies to 

current registrants in the SAM system.

2. Flexibility with application deadlines (2 CFR § 200.202)

NIDILRR will not be extending application deadlines for FY 2020 grant solicitations published on 

grants.gov. 

DEPARTMENT OF HEALTH & HUMAN SERVICES Administration for Community Living

 Washington, D.C. 20201
3. Waiver for Notice of Funding Opportunities (NOFOs) Publication (2 CFR § 200.203)

NIDILRR does not anticipate publishing emergency NOFOs. NIDILRR’s remaining FY 2020 NOFOs 

will allow applicants at least 60 days to apply. 

4. No-cost extensions on expiring awards (2 CFR § 200.308)

This flexibility is consistent with NIDILRR’s practice (and other research grant-making agencies’ 

practice) of granting no-cost extensions to our grantees who are conducting research and 

related activities. 

For awards that are active as of March 31, 2020 and scheduled to expire prior or up to 

December 31, 2020, ACL / NIDILRR will grant an extension for up to twelve (12) months as long 

as the extension is not prohibited by statute, regulation, or terms and conditions of the award. 

No cost extension requests to the NIDILRR Project Officer must include a justification for the 

request. When applicable, the request should include sufficient explanation regarding the 

impact of COVID-19 on program activities. NIDILRR / ACL will track and document all 

approved no cost extensions granted under this authority.

5. Abbreviated non-competitive continuation requests. (2 CFR § 200.308) 

NIDILRR Annual Performance Reports -- which provide updates on grantee progress and 

justification for planned continuation awards, are due on July 1, 2020. Consistent with our 

approach outlined under items 6 and 10 in this memo, NIDILRR anticipates that grantees will 

have staff time available to complete the full Annual Performance Report (APR) by this 

established due date. If grantees do not have staff or staff time available to complete the full 

NIDILRR APR due to constraints related to COVID-19, they must contact their Project Officers by 

no later than June 1, 2020 to request an extension of the due date for their required FY 2020 

APR. If requesting such an extension, grantees must provide at least a brief statement to their 

Project Officer to verify that they are in a position to resume or restore their project activities; 

and to accept a planned FY 2020 continuation award. 

6. Allowability of salaries and other project activities (2 CFR § 200.403, 2 CFR § 200.404, 2 

CFR § 200.405)

During times of potentially limited grantee research and related activities due to COVID-19, 

NIDILRR grantees may continue to charge salaries and costs incurred for other project activities 

to current active federal awards. Such charging of salaries must be consistent with the 

grantee’s policy of paying salaries under unexpected or extraordinary circumstances. As all 

planned continuation award amounts and performance periods are finite in nature, grantees 

should not assume additional funds will be available in the future to offset salaries paid under 
this flexibility. Charging of salaries under this flexibility may result in a shortage of funds to 

eventually carry out the planned NIDILRR grant activities. NIDILRR will continue to 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 future progress reports and other 

communications. If exercising this flexibility, grantees must 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)

Under this flexibility, grantees are allowed to charge costs to their award such as cancellation of 

events or travel, or costs for 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. Recipients must 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. Grantees exercising this flexibility should not assume additional funds 

will be available if the charging of cancellation or other fees to the grant result in a shortage of 

funds to eventually carry out the planned activity, event, or travel. 

8. Prior approval requirement waivers(2 CFR § 200.407)

Some prior approval requirements not already addressed in this document may be waived as 

necessary. Grantees should contact their project officers with specific questions about prior 

approval waivers not addressed under other numbered flexibilities in this memo. 

9. Exemption of certain procurement requirements (2 CFR§ 200.319(b), 2 CFR§ 200.321)

Please contact your NIDILRR Project Officer if you have any questions about this potential 

flexibility.

 

10. Extension of financial and other reporting (2 CFR§ 200.327, 2 CFR§ 200.328)

Under this item, NIDILRR may allow grantees to delay submission of financial, performance and 

other reports up to three months beyond the normal due date. As discussed under item 5 in this 

memo, NIDILRR Annual Performance Reports (APRs) are due on July 1, 2020. NIDILRR 
anticipates that grantees will have staff time available to complete the full Annual Performance 

Report (APR) by this established due date. If grantees do not have staff or staff time available to 

complete the full NIDILRR APR due to constraints related to COVID-19, they must contact their 

Project Officers by no later than June 1 to provide details about these constraints and request an 

extension of the due date. If granted such an extension, grantees must provide at least a brief 

statement to their NIDILRR Project Officer to verify that they are in a position to resume or 

restore their project activities; and to accept a planned FY 2020 continuation award. If a 

grantee receives an extension under this flexibility, they must submit their report at the end of 

the extension period. 

11. Extension of currently approved indirect costs rates (2 CFR§ 200.414 (c))

If exercising this flexibility, NIDILRR grantees must contact their Project Officers to inform them 

that they would like to do so.

12. Extension of Closeout (2 CFR§ 200.343)

NIDILRR grantees must contact their Project Officer to request such an extension – at least 30 

days prior to the planned end of their grant performance period.

 

13. Extension of Single Audit Submission(2 CFR § 200.512)

This flexibility does not require grantees to seek approval for such an extension. Grantees 

should maintain documentation of the reason for the delayed filing.