A: If employees can work successfully remotely, then their salary can continue to be paid on federally funded sponsored awards. For staff who normally punch in/punch out or are subject to direct supervision, the institution might consider deploying alternative forms of work verification. Alternate work verification is at the discretion of JHU managers. If the employee is working in a foreign location, check with your research administration office as sponsors vary for allowability on this.
A) Standard PPE. [New, 6/1/20]
If PPE was required to be purchased for a sponsored project as a part of standard best lab practice prior to COVID-19, it can continue to be direct charged to a grant during or after COVID-19 as well.
B) Additional PPE
PPE can be charged to sponsored awards if needed to conform with research reopening requirements and such costs are being allocated to all awards benefiting from the activity (e.g., all sponsored projects and all non-sponsored activities with similar needs are required to cover the cost of such items.) For example, if an experiment requires two individuals to stand within 6 feet of each other, any PPE needed to conduct that experiment would be an appropriate charge to the sponsored project during the re-opening phase even if no PPE for that experiment was considered necessary prior to COVID-19. Considerations for allocating these costs should include, the projects the salary/effort of the individuals is being charged to, or an allocation methodology.
C) Additional PPE – Beyond standard equipment but not required to re-open lab
Items not required for re-opening, (e.g. PPE acquired for the personal preference of the individuals involved) cannot be purchased on sponsored funds.
A: OMB guidance M-20-17 permits charging of salaries to active awards when persons cannot work at all provided it is consistent with JHU’s policy of paying salaries from all funding sources. JHU has resumed on-campus research activities starting June 15, 2020. Effective on June 16, 2020, personnel who are not able either to work remotely or on campus may not have their salary charged to sponsored awards. Personnel who are not able to work at all should also be coding their E210 records (if applicable) according to HR guidelines. While OMB subsequently issued guidance that would permit grant agencies to permit grantees to continue to charge personnel to the grant who are not working under September 2020 upon certain additional conditions, JHU has changed its pay policy and will not be relying on that later OMB guidance.
A: The University has to negotiate its fringe benefit rate on an annual basis with the federal government. Until we have negotiated a new fringe benefit rate agreement, please continue to use the current applicable fringe benefit rates in our existing agreement for your proposal submission. In situations where the finalized rate is lower than the budget proposed rate, generally, these excess funds are available for re-budgeting. However, it depends on each grantor’s policy. Please consult specific agency guidelines /terms and conditions of the agreement before proceeding.
A: NIH has indicated that if project-purchased PPE (or other lab supplies) were donated during the pandemic for clinical or first responder use, then the award may re-purchase PPE and charge those costs to the grant. Administrative supplements may be available if rebudgeting is inadequate to replace the donated PPE. Most other agencies require agency-prior approval to donate PPE; thus, any PPE donated should either be replaced (using non-sponsored fund sources) or the PI should request agency prior/retroactive approval. If approval is received, the replacement PPE can be charged to the award. Alternatively, non-sponsored funds can be used to purchase replacement PPE or supplies.
A: JHU previously informed the community that, in the immediate response to the COVID-19 national emergency, regardless of the funding source, personnel should continue to be paid in accordance with the University Policy Altered/Curtailed Operating Plans and the Closure. As JHU begins a phased resumption of our on-campus activities, this temporary pay policy is ending June 15, 2020, and business units must review the funding sources and pay for personnel who are not able to work.
A: Several federal agencies have issued guidance allowing for flexibility, with justification, when an institution closes. However, JHU research administration staff are fully operational remotely and do not anticipate disruption in proposal review and submission. JHU Research leadership encourages PIs to make every effort to submit proposals before the due date.