COVID-19 Revisions to Flexibilities for Federal Grants

Since March, OMB has issued four memos outlining administrative and fiscal flexibilities for federal grants management impacted by the COVID-19 pandemic:

  • M-20-11 (Issued March 9 – Expired June 16)
  • M-20-17 (Issued March 19 – Expired June 16)
  • M-20-20 (Issued April 9 – Expired June 16)
  • M-20-26 (Issued June 18 - Expires September 30)

Unfortunately, the federal government is expiring the flexibilities that were implemented starting in March.

The most significant change is related to the flexibilities to charge salaries and benefits for employees that were unable to work on grant activities (idle time).  In M-20-26, OMB included language which requires recipients to “exhaust other available funding sources” before charging salaries and benefits for employees unable to perform their duties due to COVID-19.  All federal agencies have adopted these limitations.

Unfortunately, the federal government has not provided detailed guidance for this provision. Due to the lack of guidance on what is defined by “exhaust other available funding sources” and how to provide proof of this requirement, our campus can no longer allow idle time to be charged to federal awards after June 17, 2020.  Many institutions of higher education have adopted similar internal policies prohibiting the charging of idle time to federal awards after the expiration of M-20-20 on June 16. Idle time charges from March 19 through June 16 are allowable, as long as the charges conform to the University’s   COVID-19 policy.

The Office of Grants and Contracts (OGC) will be working directly with departments that have charged idle time on or after June 17 to federally funded awards.

As other flexibilities also expired, below is a table that identifies and describes the flexibilities applicable to administrative units, the source guidance, and the expiration date for each flexibility.





Pre-Award Spending


June 16, 2020

Awarding agencies may allow necessary pre-award costs for all federal awards

No-cost extension on expiring awards

M-20-11; M-20-17

June 16, 2020

Awarding agencies may extend awards which are active as of March 31,2020 and scheduled to expire prior or up to December 31, 2020 an automatic no-cost extension

Abbreviated non-competitive continuation requests

M-20-11; M-20-17

June 16, 2020

Awarding agencies may accept a brief statement for non-competitive continuation requests for scheduled requests between April 1, 20202 and December 31, 2020. Agencies were requested to post their specific instructions on their website.

Expenditure of Award Funds for Salaries and Other Project Activities

M-20-11; M-20-17; M-20-26

June 16, 2020*

Allows for idle time charges consistent with University policy. M-20-26 extends this flexibility until September 30, 2020; however, language was added that recipients must "exhaust other available funding sources" before charging idle time. *The University of Colorado prohibits the charging of idle time after June 16, 2020.

Waivers from Prior Approval Requirements

M-20-11; M-20-17

June 16, 2020

Allows for federal agencies to waive some prior approval requirements

Exemption of certain procurement requirements

M-20-11; M-20-17

June 16, 2020

Allows agencies to waive requirements for geographical preferences and contracting with small and minority businesses, women's business enterprises, and labor surplus are firms

Extension of financial and other reporting

M-20-11; M-20-17

June 16, 2020

Federal agencies may delay the submission of financial and other reports up to three months beyond the normal due date

Flexibility with application deadlines


June 16, 2020

Agencies may provide flexibility with the regard to submission of competing applications and unsolicited applications

Allowability of costs not normally chargeable to awards


June 16, 2020

Agencies may allow recipients to incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the project

Extension of closeout


June 16, 2020

Agencies may allow recipients to delay submission of any pending financial, performance and other reports required for closeout up to one year

Donations of medical equipment and supplies for COVID-19 response



Agencies may allow recipients to donate medical equipment purchased under a federal award to hospitals, medical centers, and other local entities serving the public for COVID-19 response

Please note, while some flexibilities may be extended through December 2020, recipients must have submitted their request to the federal awarding agency or pass-through entity by June 16. Most federal agencies have developed a COVID-19 grants management policy page explaining each agency’s implementation of the flexibilities. The NIH’s COVID-19 information page provides the latest guidance and FAQs for award proposals and grant administration.


EXCERPT from M-20-26 – Allowability of Salaries and Other Project Activities

  1. Allowability of Salaries and Other Project Activities. (2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405) 
Awarding agencies may allow recipients to continue to charge salaries and benefits to active Federal awards consistent with the recipients' policy of paying salaries ( under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Awarding agencies may 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. Awarding agencies 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. Under this flexibility, payroll costs paid with the Paycheck Protection Program (PPP) loans or any other Federal CARES Act programs must not be also charged to current Federal awards as it would result in the Federal government paying for the same expenditures twice. Awarding agencies must require 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. Due to the limited funding resources under each federal award to achieve its specific public program goals, awarding agencies must inform recipients to 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. Recipients should retain documentation of their efforts to exhaust other funding sources and reduce overall operational costs.
CMS Login