Tracker Entry #: 29
Document Category: Notice of Information
Agency Actions: No approval or action needed by CDC
On March 19, 2021, the Office of Management and Budget (OMB) issued Memorandum M-21-20pdf iconexternal icon, which addresses administrative relief for applicants and recipients of COVID-19 related federal financial assistance and those applicants and recipients affected by the COVID-19 pandemic. The memorandum identifies administrative flexibilities to help
manage administrative, financial management, and audit requirements under 2 CFR Part 200. This guidance will reference the parallel sections found in the Department of Health and Human Services (HHS) grant regulations at 45 CFR Part 75, which are applicable to CDC recipients
CDC has released flexabilities from M-21-20 and apply not only to COVID-19 related assistance but also those not related to COVID-19.
Analysis/ Additional Details:
SAM Registration-CDC has relaxed the requirement for active System for Award Management (SAM) registration at time of application in order to expeditiously issue funding
Waiver for Notice of Funding Opportunities (NOFOs) Publication-CDC will make every effort to provide applicants with adequate time to submit quality applications, should additional funding become available for COVID-19 competitive NOFOs. However, applicants should be aware that CDC may publish emergency and competitive NOFOs for less than 30 days if CDC needs to expedite the processApplicants may search for applicable funding opportunities at www.Grants.gov
Pre-award costs– If within the scope of the award, CDC may allow necessary pre-award costs that are incurred (i) from March 15, 2021, through the Public Health Emergency Period and (ii) prior to the effective date of a federal award.
No-cost extensions on expiring awards– CDC may extend awards that were active as of March 31, 2021, and scheduled to expire prior or up to December 31, 2021, automatically at no cost for a period of up to 12 months.
Abbreviated non-compteitive continuation requests– CDC may accept a brief statement from recipients for non-competitive continuation requests scheduled to come in from April 1, 2021, to December 31, 2021, for projects with planned future support. CDC programs will post any specific instructions in their continuation guidance.
Waivers from prior approval requirements– CDC may waive prior approval requirements as necessary to effectively address the response. All costs charged to federal awards must be consistent with federal cost policy guidelines and the terms of the award, except where specified in Memorandum M-21-20.
Exemption of certain procurement requirements– CDC waives the procurement requirements contained in 45 CFR § 75.328(b) regarding geographical preferences and 45 CFR § 75.330 regarding contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms. This exemption is limited to these specific procurement requirements
Extension of financial and other reporting– CDC may allow recipients to delay submission of financial or other reports up to 3 months beyond the normal due date
Extension of single audit submission– CDC recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of OMB Memorandum M-21-20pdf iconexternal icon that have fiscal year-ends through June 30, 2021, may delay the completion and submission of the Single Audit reporting package to 6 months beyond the normal due date.
Flexibilities with application deadlines– When a delay occurs because the applicant or recipient is directly impacted by COVID-19, CDC will consider extending the application due date beyond the date specified in the Notice of Funding Opportunity (NOFO) on a case-by-case basis
Extension of closeout– On a case-by-case basis, CDC may allow the recipient to delay submission of any pending financial, performance, or other reports required by the terms of the award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the recipient to the agency
Management Requirement related to Physical Inventories-On a case-by-case basis, CDC may provide recipients up to a 12-month extension for the biennial physical inventory of equipment purchased under a federal award.