Several awardees have notified the Office of Nuclear Energy's (NE) Nuclear Energy University Program (NEUP) about potential delays in execution of their awards due to facility (university buildings, laboratories, industry) closures, in wake of the COVID-19 national emergency.
The DOE Policy Flash (PF) 2020-20, which is the Department of Energy's (DOE) implementation of Office of Management and Budget Memorandum M-20-17 entitled, "Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations," dated March 19, 2020 (https://www.energy.gov/management/downloads/pf-2020-20-covid-19-guidance-financial-assistance-actions), provides information to financial assistance award recipients clarifying several procurement-related topics, including no-cost extensions, allowability of salaries and other project activities, allowability of costs not normally chargeable to awards, and the extension of financial, performance, and other reporting requirements. Additional information on these topics is included below.
No-Cost Extension (NCE):
Awards that are operating in the original period of performance (FY17–FY19 awards), and are active as of March 31, 2020 and scheduled to expire on or before December 31, 2020, are eligible for an NCE.
For awards that are operating in a current NCE (FY16 CINR awards), the PF provides new guidance that allows Contracting Officer (CO) authorization to extend awards for recipients who have already utilized the one-time extension as provided in 2 CFR 200.308(d)(2), are still active as of March 31, 2020, and are scheduled to expire on or before December 31, 2020.
Instructions on how to apply for an NCE are available here.
Allowability of Salaries and Other Project Activities:
Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active DOE awards consistent with the recipient's policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Recipients are authorized to charge other costs to DOE awards that are necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. Recipients must not assume that supplemental funding will be available should the charging of such costs or other fees result in a shortage of funds to eventually carry out the project.
If a funding shortfall is anticipated, recipients must contact the cognizant DOE CO to address the situation. DOE will evaluate the recipient's ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances—based on subsequent project reports and other communications with the recipient. Recipients are required 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.
Extension of Financial, Performance, and Other Reporting:
Recipients must inform the DOE-ID Procurement contact listed below if they require an extension for the submission of any pending periodic financial, performance, and other reports required by the terms of the award. DOE will extend the due dates for the submission of financial, performance, and other reports for up to three (3) months. Recipient periodic financial, performance, and other reporting requirements due between March 1 and August 1, 2020 can be extended up to 3 months from the date required in their awards. These reports must be submitted in accordance with the terms and conditions of the award.
If you have questions concerning an NCE, please contact Tara Haack (DOE-ID) at 208-526-1960 or email@example.com or Anna Podgorney (INL-IO) at 208-526-2123 or firstname.lastname@example.org. For all other questions (e.g., report deadline extension, allowability of salary, and other project activities) please contact Alden Allen (DOE-ID Procurement) at 208-526-4154 or email@example.com.