All research activity needs a detailed request for an exception sent to Jill Pipher, VP OVPR for review and approval (with copies to Dean Ed Hawrot and Dean Elias). Prior to sending to OVPR the exception justification needs to be reviewed and approved by the department chair. If approved the proposed research activity then needs to be added to the lab's minimal maintenance plan.

Jill Pipher, VP OVPR, is reviewing and approving all proposals that would require the re-opening of laboratories. PIs should email Jill Pipher if they want to re-open or ramp-up a closed lab, or research project for both COVID-19 related and non-COVID-19 research (with copies to Dean Ed Hawrot and Dean Jack Elias).

Yes. The continuous submission policy applies to NIH applications submitted by a PI or MPI with CS privileges to R01, R21 and R34 FOAs with standard due dates. Normally, NIH would accept CS applications until April 10. However, NIH will now accept such applications (non-AIDS) through May 1, 2020 per NOT-OD-20-091.

Non-refundable costs associated with grant-related travel that has been cancelled due to COVID-19 may be charged to the NIH/NSF awards if they would have otherwise been allowable. If vouchers have been granted for any of the travel expenses affected by COVID-19, faculty/staff are required to use the vouchers and may not request additional support.  Brown must document that costs charged to a grant are non-refundable and maintain documentation, in accordance with record retention requirements. Faculty should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel. Please contact BMRA for guidance if federal agency other than HHS/NSF.

If salary charges to grants for reassigned employees are permissible, what type of policy will the institution need to have in place to do this? Can stipends of trainees still be charged if they are similarly reassigned? What if personnel are reassigned to COVID research instead of clinical care activities?

NIH will permit salaries of personnel who have been reassigned to providing clinical care to COVID-19 patients to continue to be charged to NIH grants, if permitted under institutional policy. The institution must have internal institutional policies (which can include emergency policies, internal guidance and best practices) that permit charging of salaries and benefits in extraordinary circumstances regardless of funding source. NIH prior approval is not required for such reassignment, but if the reassignment causes a Program Director/Principal Investigator to be absent from a project for three or more months, the institution must notify the IC to identify a temporary replacement until the public health emergency is over, or the research will be placed on hold and delays reported in the RPPR. [NIH COVID FAQ, Section VI.C.3. (“Charging salaries to NIH grants when no work is being performed is allowable if your organization’s policy allows for the charging of salaries and benefits to currently active awards (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal.”)].

Similarly, stipends for trainees can continue to be paid if the trainee cannot work on training activities because COVID. Trainees can be reassigned to engage in clinical care activities for COVID patients, but NIH policies limit the amount of time trainees can spend on these additional activities to 25% of total time, and the additional activities may not interfere with or lengthen the training. [NIH COVID FAQ, Section VI.C.2.; NIH NOT-OD-17-095].

NIH draws a distinction between providing clinical care for COVID patients and involvement in COVID research. NIH has stated that providing clinical care for COVID patients is a priority for all institutions and the NIH. COVID research is also a priority, but researchers must follow normal NIH procedures for determining whether or not the proposed COVID research falls within the scope of the research contemplated by the originally awarded grant. If the COVID-related activities are within the scope of the original grant, then activities may proceed, and an administrative supplement to provide additional funding may be provided if the IC believes that the change is worthwhile. If, however, the COVID related research is outside the scope of the original grant, then a competitive revision would need to be submitted. [NIH Grants Policy Statements Sections 8.1.2.5 & .12]. NIH has emphasized that although certain processes are being streamlined to address exigencies arising during this public health emergency, other processes remain in effect and unchanged, and all award recipients must take care to remain good stewards of federal funds. [See, NIH COVID FAQ, Section VI.C.3 & D.5].

Recipients should document COVID-19 effects and state that research outcomes are not available at this time. Recipients should outline when they believe they will be able to include details related to the disruptions to the research efforts. [(“NIH COVID FAQ”), Section IV].

NIH understands the potential effects of COVID-19 on the progress of NIH supported research. Recipients must contact the funding IC to alert them of any effects on the NIH funded research. NIH is committed to working with its applicants and recipients during this public health emergency. In addition, NIH recognizes that there may be delays in submission of RPPRs and other reports. See NOT-OD-20-086 for details on late submission. [(“NIH COVID FAQ”), Section IV].

NIH will permit carry-over of trainee support funds as part of the flexibilities it has extended concerning training, fellowship and career development awards. NOT-OD-20-086 states that “recipients may extend awards affected by COVID-19” by notifying the funding Institute or Center (IC). Even in the case of phased awards where extensions are usually limited, NIH may consider extensions, including extensions for obtaining faculty positions. [See COVID-19 Flexibilities FAQs, Section IX, Questions 1 and 2.] In these cases, the recipient should write to the IC and provide details. Similarly, recipients may contact the IC to request extensions to National Research Service Awards and fellowships, as well as an extension of the period in which to apply for a K99 Pathway to Independence Award. [See COVID-19 Flexibilities FAQs, Section IX, Questions 5 and 7.]