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CORONAVIRUS (COVID-19) FREQUENTLY ASKED QUESTIONS

Research and Evaluation (and SIF) Questions

Last update 8/21/20

AmeriCorps is closely monitoring the latest developments related to COVID-19. As America responds to 

the COVID-19 pandemic, you may have concerns about the potential impacts on your program. The 

below FAQs address questions posed by the outbreak. Check back as they are updated regularly.

These FAQs do not have the force and effect of law and are not meant to bind the public in any way. 

This document is intended only to provide clarity to the public regarding existing requirements under the 

law or agency policies. You should refer to AmeriCorps’ statute and regulations for applicable 

requirements.

Information for Research Grantees:

1. As an AmeriCorps research grantee, what do I do if my work plan changes due to 

cancelations at the university and community events?

If you are a 2015 or 2017 National Service and Civic Engagement Research Grantee or a 2018 

Community Conversations Research Grantee and your work plans will be affected due to 

public health concerns associated with COVID-19, please contact your AmeriCorps Program 

Officer by email with specific information regarding your situation and anticipated impacts.

[updated 3/13]

2. As a 2017 National Service and Civic Engagement Research Grantee completing the third 

year of a grant, can we apply for a no-cost extension if my work plan changes due to 

cancelations at the university and at other organizations associated with my research? 

If you are a 2017 National Service and Civic Engagement Research third-year grantee you are 

able to request up to a one-year, no cost extension. Please contact your AmeriCorps Program 

Officer by email with specific information regarding your situation and anticipated impacts. 

[updated per 2 C.F.R. § 200.308(d)(2)]

3. Will Community Conversations funding for the 2018 cohort awarded in FY19 carry forward 

into FY21?

If you are unable to utilize all of the funding you received in FY19, please have your authorized 

representative and project director provide your program officer and grants officer with a 

rationale and the amount you want to carry forward into year three. No cost extensions and 

carrying funds forward require prior written approval subject to 2 C.F.R. 200.308(d)(2) and 

(d)(3). [updated 5/12]
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Information for Social Innovation Fund (SIF) Grantees:

1. As a AmeriCorps Social Innovation Fund 2015 or 2016 grantee, what do I do as the Program 

Lead if implementation of my awarded application, subgrantee work plan, or approved 

evaluation study design and communication plan is impacted due to COVID-19 public health 

concerns?

If you are a 2015 or 2016 Social Innovation Fund grantee and your funded and approved 

application work plans will be affected due to public health concerns associated with COVID19, please contact your AmeriCorps Program Officer by email with specific information 

regarding your situation and anticipated impacts. [updated 3/13]

2. We are sharing our expectations with our SIF subgrantees, specifically related to time 

reporting. In terms of verification of the time and activities performed, we’re looking at options 

to validate claimed hours when subgrantees are unable to complete normal business 

practices. It is our understanding that our subgrantee staff are working remotely, however 

some of their existing grants management processes are a bit ill-suited for teleworking. For 

those that may not have an electronic timekeeping system or typically use hard copy 

timesheets, would an email from a staff person to their supervisor, noting the dates and time 

spent on SIF activities – with a subsequent email from the supervisor “approving” be sufficient 

documentation?

Yes, Uniform Guidance 2 CFR 200.430 does not require time sheets, just the recording of time 

for a specific employee with percentage breakdown on all activities, both Federally funded 

and non-Federally funded, and the assurance that it is accurate, allowable, and properly 

allocated. This allows for you and your subawards to have some flexibility on how exactly how 

you will document timekeeping and chargeable activity information.

Grantees and subgrantees should follow their internal policies for timekeeping and verifying 

timesheets when an employee is not available to sign their timesheet. If a policy is not in 

place, there are alternative ways to create those records. Employees who are teleworking 

may submit alternative written submissions to their supervisor noting hours they have served. 

Rather than using a timesheet, their submissions may be sent, for example, via email. The 

supervisor may, in turn, approve each submission by sending a response back to the 

employee with a notation such as “Hours submitted approved”. In addition to the emailed 

information and approvals themselves, both you as the Grantee and the subawards should 

document the temporary change in timekeeping practices in an internal memo kept for their 

records and yours.

Uniform Guidance:

2 CFR 200.430(h)(8)(i) requires non-Federal entities to maintain records that “accurately reflect 

the work performed.” These records must:
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• Be supported by a system of internal control which provides reasonable assurance that 

the time being charged is accurate, allowable, and properly allocated

• Are incorporated in the official records, such as payroll records

• Reasonably reflect the employee’s total activity

• Provide a time or percentage breakdown on all activities, both Federally funded and 

non-Federally funded, for the employee

• Comply with the non-Federal entity’s pre-established accounting practices and 

procedures

• As stated at 2 CFR 200.430(h)(8)(i), non-Federal entities that cannot meet the 

aforementioned conditions may be required to submit personnel activity reports.

[updated 6/29]

3. Can SIF grantees be given a no-cost extension due to COVID-19? Can our deadline to draw 

down federal funds and report by our closeout date would be extended?

This question has two parts. Recipients can request a no-cost extension pursuant 2 C.F.R. § 

200.308(d)(2). Further, funds that were obligated within their period of availability are available 

to liquidate obligations for a period of five years after the date of expiration. See 31 U.S.C. § 

1552(a). Thus, grantees can draw down on the funds for five years, at which point the account 

will close and the funds will be cancelled. SIF cohort 2015 and 2016 grantees were not given 

continuation funding, and therefore are operating on only one five-year funding strip. For a SIF 

grantee this means that funds that are not spent and drawn down by the conclusion of this 

five-year period will be automatically recovered by the U.S. Treasury and that you and your 

team will be unable to draw them down from the Payment Management System (PMS). A nocost extension would not change this. [updated 4/2]

4. Our SIF award is in the final program year, and we are beginning to closeout our 

subgrantees. Could we extend our SIF subawards to continue serving the participants and 

draw on federal funds (if matching funds are available)?

Per 2 CFR 200.308, if your subawards have not closed out yet, you can extend your remaining 

SIF subgrantee agreements, as long as your own internal SIF policies and guidance supports 

granting a no-cost extension. However, you cannot extend them past the current period of 

performance end date of your federal award. You need to inform your PO of the extension in 

writing, but it does not require the PO’s approval. [updated 4/2]

5. During this COVID-19 national emergency most subgrantees are physically closed and 

serving clients remotely, which could have an impact on their ability to spend funds. What 

guidance can be given to subgrantees on expanded ways to perform during the national 

emergency. Are there creative ways AmeriCorps and AmeriCorps Seniors grantees are 

performing during this time to support subgrantees? 

Creating guidance for subgrantees on reasonable, allowable, and allocable chargeable 

programmatic activities that are within your awarded scope of work during the COVID-19 

national emergency is a good way to codify the impact and expectations and ensure fidelity 
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to your model. Each SIF award is unique in the intervention type, model, and approved 

evaluation plan. Think about chargeable activities that could be programmed in an online 

platform: 

• Build on the work that is typically presented face-to-face by investigating options for 

moving to telephonic, email, or Facetime formats. 

• Discuss with your subgrantees the wrap-around services needed to help meet the 

requirements of their enrolled participants. 

• As you discuss community needs with your subgrantees, look into creating online 

webinars to share key community information with enrolled participants in a 

neighborhood format. 

If, as a grantee, you are seeking to make changes to just the format/presentation of the 

programming rather than the scope of the awarded programming, your programming 

policies and guidance should include the context in which you are making the changes, how 

they are within scope, and the estimated timing and circumstances in which you revert to 

previous standard operating procedures. 

If you are considering making a change to the scope of your awarded grant, you must submit

a request to AmeriCorps in writing for review and approval before acting. [updated 4/15]

6. We are in the data collection stage of our approved SIF evaluation plan. Our approved plan 

will need to have some research activities modified due to COVID-19 community closures that 

will affect the volume and quality of data as well as potentially impact the research 

conclusions. What should we do as a grantee? 

Per the SIF Evaluation Guidance Update Memo (dated 8/29/2017): Changes to evaluation 

design will no longer require review and approval. Grantees should include a section in the 

final report that outlines changes to the approved evaluation design (SEP) and justification for 

why it was necessary. Completing steps 1-5 below will ensure that both your organization and 

AmeriCorps has COVID-19 specific documentation on potential changes to your research 

deliverable: 

1. Assess the impact on your approved SEP; 

2. Develop options and a mitigation strategy with your External Evaluator and 

Subgrantees; 

3. Inform your Program Officer and document the impact with a written COVID-19 plan; 

4. Seek input from the AmeriCorps Office of Research and Evaluation; and 

5. Please keep your Program Officer up-to-date on the further evaluation changes due to 

COVID-19. 

[updated 4/15] 
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7. As a 2015 SIF cohort Grantee, all of our planned convenings and conferences for the 

dissemination and sharing of evaluation results have been canceled or rescheduled for the 

fall/end of 2020 after our award period of performance ends. Is it possible to extend our grant 

given the impact on performance due to COVID-19? 

SIF cohort 2015 awards CANNOT be extended because the funding appropriated for such 

awards is subject to cancellation under 31 U.S.C. § 1552(a). As a 2015 SIF Grantee, your U.S. 

Treasury funding strip will expire at the end of July 2020. Dissemination of your evaluation results 

is a bona fide chargeable activity associated with the completion of your award. Please 

reach out to your Grants Officer and Program Officer for assistance with paying and 

documenting cancellation expenditures associated with dissemination events that can no 

longer be held during your awarded period of performance. For SIF grantees funded in 2016 

and later, however, where legally possible AmeriCorps can adjust the period of performance 

for the grant funded convening and conferences, pursuant to 2 C.F.R. §§ 200.308(d)(2) and 

.308(d)(3). Please submit any such request to your Grants Officer and copy your Program 

Officer. [updated 6/29]

8. If our employees cannot report to work or telework because of COVID-19, are their salaries 

and benefits an eligible cost?

Yes, under certain conditions, it is allowable to continue to pay staff members their hourly pay 

or salaries under the grant. If a grant recipient’s policies allow the grantee to continue to 

charge staff hourly pay or salaries during a period when no work is performed due to 

unexpected or extraordinary circumstances, then such charges to the grant award are 

allowable through September 30, 2020. The grantee’s policy must allow the grantee to 

continue to charge wages and salaries regardless of the funding source, including Federal 

and non-Federal sources. These pay policies must also be applicable to the grant recipient’s 

entire workforce.

Originally, this pay action was valid for a 90-day period consistent with the March 19, 2020 

memorandum issued by the Office of Management and Budget (OMB) that provides federal 

grant awarding agencies, such as AmeriCorps, the authority to provide short term 

administrative relief to grant recipients affected by the loss of operational capacity and 

increase costs due to COVID-19. The 90-day period expired on June 18, 2020. See OMB 

Memorandum M-20-26.

On June 18, 2020, OMB issued a follow-on memorandum extending AmeriCorps’ authority to 

provide this short-term administrative relief, to September 30, 2020. See OMB Memorandum M20-26.

As provided in the June 18, 2020 OMB memorandum, AmeriCorps is authorized, through 

September 30, 2020, to allow grant recipients to continue to charge salaries and benefits to 

active grant awards consistent with the grant recipient's policy of paying salaries (under 

unexpected or extraordinary circumstances) from all funding sources. Please note that under 

this continued pay flexibility, payroll costs paid with the Paycheck Protection Program (PPP) 
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loans or any other Federal CARES Act programs must not be also charged to current Federal 

awards as doing so would result in the Federal government’s paying for the same expenditures 

twice.

Please also note that due to the limited funding resources under each federal award to 

achieve its specific public program goals, AmeriCorps and AmeriCorps Seniors grant recipients 

must first 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. See OMB 

Memorandum M-20-26.

AmeriCorps may also 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.

Finally, as required by 2 CFR § 200.302 Financial Management and 2 CFR § 200.333 Retention 

Requirement of Records, grant recipients are required to continue to maintain appropriate 

records and documentation to support the hourly pay or salary charges that it made against 

the grant. This complies with OMB’s cost principle requirements that require grant recipients to 

maintain appropriate records and cost documentation to substantiate charging hourly pay or 

salaries or other project activity costs related to the interruption of operations or services. 2 CFR 

§§ 200.302, 200.333. [updated 6/26]

9. Some AmeriCorps programs have waived their award match requirements due to the 

impact of COVID-19 on the grantee organization and communities in which the grantees are 

funded. Will AmeriCorps waive the Social Innovation Fund (SIF) award match requirement due 

to COVID-19?

SIF Grantees may seek a reduction in match under the SIF Match Reduction Policy and 

Process Memorandum (“Match Reduction Policy” dated 10/1/2014). The Match Reduction 

Policy states that per 42 U.S.C. § 12653k(i)(3) “[t]he Corporation may reduce by 50 percent the 

matching funds required by paragraph (1) for an eligible entity serving a community that the 

eligible entity can demonstrate is significantly philanthropically underserved.” 

This definition is applied on a community-by-community basis, not to the overall Grantee 

portfolio. That said, it is possible that a place-based Grantee’s entire portfolio could be 

located in one community. A significantly philanthropically underserved community is defined 

as:

(a) considerably less than the average number of active philanthropic institutions or 

investments, or 

(b) a community can become significantly philanthropically underserved if it is affected by an 

unexpected natural or man-made event that redirects or otherwise reduces the availability of 

match funds (e.g. disaster, loss of major local employer, etc.).
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The Match Reduction Policy requires eligible, individual SIF Grantees to make a REQUEST in 

writing to receive a match waiver from AmeriCorps. The SIF Grantee must state in the request: 

• The circumstances for the match reduction request

• The timeframe for the reduction

• The amount of the reduction requested, and 

• Demonstrate in a plan, how the approval will allow them to substantively contribute to 

their or their subgrantee’s efforts as defined by their approved work plans and 

agreements

• The Grantee should also describe the expected impact on their programming if the 

request is denied. 

SIF Grantees in cohorts 2016 seeking a match reduction must apply to their Grants Officer and 

copy their Program Officer to receive a review and potential approval of their application. 

Those receiving match reductions will be instructed on how to create an amendment 

associated with the approved amounts. [updated 6/9]

10. Can a SIF award recipient use funds from a Paycheck Protection Program (PPP) loan as the 

SIF match requirement? 

No, 42 U.S.C. § 12653k(k)(2) states that matching funds are required by law to be non-federal 

cash, therefore federal PPP funds cannot be used for the SIF match. [updated 6/9]

11. Our SIF subgrantees have shared their challenges in completing sustainability activities due 

to the disruption caused by COVID-19. A no-cost extension would respond to these challenges 

by providing the ability to extend our subgrantees’ grant terms using solely match funds. Given 

these circumstances alongside the core SIF principle of sustainability, can we apply for a nocost extension consistent with those parameters established in 2 C.F.R. 200.308(d)(2)? 

There are several factors to consider in order to answer this question:

a. The SIF was no longer appropriated by Congress starting in FY 2018. AmeriCorps allowed 

SIF Grantees with awarded multi-year grants and active periods of performance to 

continue their awarded and operationalized plans through no later than December 31, 

2020. 

b. 2015 Cohort and 2016 Cohort SIF Terms and Conditions (dated 10/1/2018) were 

updated to state, “Pursuant to 2 C.F.R. 200.308(d)(2)(i), AmeriCorps specifically prohibits 

SIF Classic and SIF Pay for Success grantees from initiating a one-time extension of the 

performance periods of their grant awards and will not approve any requests for an 

extension of the performance period of the SIF Classic and SIF Pay for Success grants.”

c. Each of the 2015 and 2016 Cohort SIF Grantees’ Funds were obligated within their 

period of availability and are available to liquidate obligations for a period of five years 

[See 31 U.S.C. § 1552(a)] at which point the funds will be cancelled.

AmeriCorps would like to be as flexible as possible in our administrative relief efforts, but there 

are costs and risks associated with our agency’s oversight of SIF awards that involve federal 
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programmatic and grants officer monitoring and oversight, risk management and mitigation, 

and evaluation support work. 

Due to extraordinary circumstances, AmeriCorps will allow a SIF Grantee to REQUEST a timelimited, no cost extension for 2016 cohorts, if the following conditions are met: 

• The grantee or subgrantee are spending only budgeted Match Funds per their currently 

approved budget.

• An Intermediary and/or subgrantee extension was needed to meet a SIF statute 

component of scaling, sustainability, or evaluation.

• The quantifiable time needed (no greater than 6 months) for the extension could be 

defined and subgrantee agreement work plans associated with that time show the 

need reinforced by community delays associated with COVID-19.

• The amendment required to provide the no cost extension will document the delays, 

the complete execution and draw of federal funds prior to the end of the current 

period of performance, and the needed reason. 

• The request is a one-time exception, include documentation that the need is COVID-19 

related, and must be approved by your Grants and Program Officer through a formal 

amendment in eGrants. 

[updated 6/29]