Research and Evaluation and SIF Questions

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The below Frequently Asked Questions address many issues posed by the COVID-19 outbreak. Check back as they are updated regularly.

Printable versions can be downloaded below. The most recently updated FAQs are highlighted in blue.

Last update 5/12/20


Information for Research Grantees:

1. As a CNCS research grantee, what do I do if my work plan changes due to cancelations at the university and community events?
If you are a 2015 or 2017 National Service and Civic Engagement Research Grantee or a 2018 Community Conversations Research Grantee and your work plans will be affected due to public health concerns associated with COVID-19, please contact your CNCS Program Officer by email with specific information regarding your situation and anticipated impacts. [updated 3/13]

 

2. As a 2017 National Service and Civic Engagement Research Grantee completing the third year of a grant, can we apply for a no-cost extension if my work plan changes due to cancelations at the university and at other organizations associated with my research?
Consistent with OMB’s Memorandum “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations,” issued March 19, 2020, if you are a 2017 National Service and Civic Engagement Research third-year grantee you are able to request a one-year, no cost extension. Please contact your CNCS Program Officer by email with specific information regarding your situation and anticipated impacts. [updated 3/24]

 

3. Will Community Conversations funding for the 2018 cohort awarded in FY19 carry forward into FY21?
If you are unable to utilize all of the funding you received in FY19, please have your authorized representative and project director provide your program officer and grants officer with a rationale and the amount you want to carry forward into year three. No cost extensions and carrying funds forward require prior written approval subject to 2 C.F.R. 200.308(d)(2) and (d)(3). [updated 5/12]

 

Information for Social Innovation Fund Grantees:

1. As a CNCS Social Innovation Fund 2015 or 2016 grantee, what do I do as the Program Lead if implementation of my awarded application, subgrantee work plan, or approved evaluation study design and communication plan is impacted due to COVID-19 public health concerns?
If you are a 2015 or 2016 Social Innovation Fund grantee and your funded and approved application work plans will be affected due to public health concerns associated with COVID-19, please contact your CNCS Program Officer by email with specific information regarding your situation and anticipated impacts. [updated 3/13]

 

2. We are sharing our expectations with our SIF subgrantees, specifically related to time reporting. In terms of verification of the time and activities performed, we’re looking at options to validate claimed hours when subgrantees are unable to complete normal business practices. It is our understanding that our subgrantee staff are working remotely, however some of their existing grants management processes are a bit ill-suited for teleworking. For those that may not have an electronic timekeeping system or typically use hard copy timesheets, would an email from a staff person to their supervisor, noting the dates and time spent on SIF activities – with a subsequent email from the supervisor “approving” be sufficient documentation?
Uniform Guidance 200.430i does not require time sheets, just the recording of time for a specific employee with percentage breakdown on all activities, both Federally funded and non-Federally funded, and the assurance that it is accurate, allowable, and properly allocated. This allows for you and your subawards to have some flexibility on how exactly how you will document timekeeping and chargeable activity information.

Grantees and subgrantees should follow their internal policies for timekeeping and verifying timesheets when an employee is not available to sign their timesheet. If a policy is not in place, there are alternative ways to create those records. Employees who are teleworking may submit alternative written submissions to their supervisor noting hours they have served. Rather than using a timesheet, their submissions may be sent, for example, via email. The supervisor may, in turn, approve each submission by sending a response back to the employee with a notation such as “Hours submitted approved”. In addition to the emailed information and approvals themselves, both you as the Grantee and the subawards should document the temporary change in timekeeping practices in an internal memo kept for their records and yours.

Uniform Guidance:
2 CFR 200.430(i) requires non-Federal entities to maintain records that “accurately reflect the work performed.” These records must:

  • Be supported by a system of internal control which provides reasonable assurance that the time being charged is accurate, allowable, and properly allocated
  • Are incorporated in the official records, such as payroll records
  • Reasonably reflect the employee’s total activity
  • Provide a time or percentage breakdown on all activities, both Federally funded and non-Federally funded, for the employee
  • Comply with the non-Federal entity’s pre-established accounting practices and procedures
  • As stated at 2 CFR 200.430(i)(8), non-Federal entities that cannot meet the aforementioned conditions may be required to submit personnel activity reports. [updated 3/20]

 

3. If our SIF Award were to ask for a no-cost extension due to COVID-19, is there any indication that our deadline to draw down federal funds and report by our closeout date would be extended?
This question has two parts. OMB’s Memorandum “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations” (titled M-20-17), issued March 19, 2020, allows for some latitude in what federal agencies can offer to their active awards impacted by COVID-19, to include a no-cost extension. Funds were obligated within their period of availability and are available to liquidate obligations for a period of five years after the date of expiration. See 31 U.S.C. § 1552(a). M-20-17 did not change this. Thus, grantees can draw down on the funds for five years, at which point the account will close and the funds will be cancelled. SIF cohort 2015 and 2016 grantees were not given continuation funding, and therefore are operating on only one five-year funding strip. For a SIF grantee this means that funds that are not spent and drawn down by the conclusion of this five year period will be automatically recovered by the U.S. Treasury and that you and your team will be unable to draw them down from the Payment Management System (PMS). A no-cost extension would not change this. [updated 4/2]

 

4. Our SIF award is in the final program year, and we are beginning to closeout our subgrantees. Could we extend our SIF subawards to continue serving the participants and draw on federal funds (if matching funds are available)?
Per 2 CFR 200.308, if your subawards have not closed out yet, you can extend your remaining SIF subgrantee agreements, as long as your own internal SIF policies and guidance supports granting a no-cost extension. However, you cannot extend them past the current period of performance end date of your federal award. You need to inform your PO of the extension in writing, but it does not require the PO’s approval. [updated 4/2]

 

5. During this COVID-19 national emergency most subgrantees are physically closed and serving clients remotely, which could have an impact on their ability to spend funds. What guidance can be given to subgrantees on expanded ways to perform during the national emergency. Are there creative ways CNCS grantees are performing during this time to support subgrantees? 
Creating guidance for subgrantees on reasonable, allowable, and allocable chargeable programmatic activities that are within your awarded scope of work during the COVID-19 national emergency is a good way to codify the impact and expectations and ensure fidelity to your model. Each SIF award is unique in the intervention type, model, and approved evaluation plan. Think about chargeable activities that could be programmed in an online platform: 

  • Build on the work that is typically presented face-to-face by investigating options for moving to telephonic, email, or Facetime formats.
  • Discuss with your subgrantees the wrap-around services needed to help meet the requirements of their enrolled participants. 
  • As you discuss community needs with your subgrantees, look into creating online webinars to share key community information with enrolled participants in a neighborhood format. 

If, as a grantee, you are seeking to make changes to just the format/presentation of the programming rather than the scope of the awarded programming, your programming policies and guidance should include the context in which you are making the changes, how they are within scope, and the estimated timing and circumstances in which you revert to previous standard operating procedures. 

If you are considering making a change to the scope of your awarded grant, you must submit a request to CNCS in writing for review and approval before acting.[updated 4/15]



6. We are in the data collection stage of our approved SIF evaluation plan. Our approved plan will need to have some research activities modified due to COVID-19 community closures that will affect the volume and quality of data as well as potentially impact the research conclusions. What should we do as a grantee?
Per the SIF Evaluation Guidance Update Memo (dated 8/29/2017): Changes to evaluation design will no longer require review and approval. Grantees should include a section in the final report that outlines changes to the approved evaluation design (SEP) and justification for why it was necessary. Completing steps 1-5 below will ensure that both your organization and CNCS has COVID-19 specific documentation on potential changes to your research deliverable:  

  1. Assess the impact on your approved SEP; 
  2. Develop options and a mitigation strategy with your External Evaluator and Subgrantees; 
  3. Inform your Program Officer and document the impact with a written COVID-19 plan; 
  4. Seek input from the CNCS Office of Research and Evaluation; and
  5. Please keep your Program Officer up-to-date on the further evaluation changes due to COVID-19.

[updated 4/15]



7. As a 2015 SIF cohort Grantee, all of our planned convenings and conferences for the dissemination and sharing of evaluation results have been canceled or rescheduled for the fall/end of 2020 after our award period of performance ends.  Is it possible to extend our grant based on OMB Memo M-20-11 or M-20-17, Appendix A - Administrative Relief Exceptions for COVID-19 Crisis (4)?
M-20-11 Appendix A - Administrative Relief Exceptions for COVID-19 Crisis and M-20-17 Appendix A - Administrative Relief Exceptions for COVID-19 Crisis , Exception (4) allows for no cost extensions for expiring awards for resumption of projects due to COVID-19 interruptions to award activities. SIF cohort 2015 awards, however, CANNOT be extended because the funding appropriated for such awards is subject to cancellation under 31 U.S.C. § 1552(a). The response to this question is similar to SIF FAQ 3. As a 2015 SIF Grantee, your U.S. Treasury funding strip will expire at the end of July 2020 and the issuance of M-20-17 does not change that. 

OMB Memo M-20-17, Appendix A - Administrative Relief Exceptions for COVID-19 Crisis (7), states that you may be allowed to incur costs associated with the cancellation of an event. Dissemination of your evaluation results is a bona fide chargeable activity associated with the completion of your award. Please reach out to your Grants Officer and Program Officer for assistance with paying and documenting cancellation expenditures associated with dissemination events that can no longer be held during your awarded period of performance. [updated 4/15]

 


8. Is paying the salaries and benefits of employees who are currently not working due to COVID-19 an eligible cost?
OMB Memorandum M-20-17 allows federal agencies to permit federal award recipients to continue to charge salaries and benefits to their awards consistent with the recipients’ policy for paying salaries and benefits under unexpected or extraordinary circumstances from all funding sources. M-20-17 permits flexibility to be passed down to subgrantees. Intermediaries must explain that the portion of salaries paid by CNCS funds must be paid according to a reasonable documented basis, and that they are unexpected or extraordinary.[updated 4/15]

 

These FAQs do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies. You should refer to CNCS’s statute and regulations for applicable requirements.

 

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