Version 2, revised: March 25, 2020; Replaces FAQs dated March 16, 2020
2
6.
Expenditure of award funds for salaries and other project activities:
• Recipients may continue to charge salaries and benefits to currently active awards consistent
with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances)
from all funding sources, Federal and non-Federal.
• USAMRAA will allow other costs to be charged to Federal awards necessary to resume activities
supported by the award, consistent with applicable Federal cost principles and the benefit to
the project. This may include allowing rent on equipment and facilities during this time frame.
o However, to the maximum extent practicable, recipients must invoke or institute any
and all reasonable mitigation actions and practices to lessen the cost to the Government
during the crisis period. Such actions may be part of an existing program created by the
recipient organization or may be created to respond to this crisis.
• Recipients must 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.
7. Allowability of Costs not Normally Chargeable to Awards.
• USAMRAA will allow recipients who incur costs related to the cancellation of events, travel, or
other activities necessary and reasonable for the performance of the award, or the pausing and
restarting of grant funded activities due to the public health emergency, to charge these costs to
their award without regard to 2 CFR § 200.403, Factors affecting allowability of costs, 2 CFR §
200.404, Reasonable costs, and 2 CFR § 200.405, Allocable costs.
• USAMRAA will allow recipients to charge full cost of cancellation when the event, travel, or
other activities are conducted under the auspices of the grant.
• However, recipients 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.
• 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 cancellation or other fees related to interruption of
operations or services.
8. Prior approval requirement waivers:
• OMB and DoD have authorized awarding agencies to waive prior approval requirements as
necessary. Some prior approvals are already waived under the DoD General Research &
Development Terms and Conditions and USAMRAA’s agency-specific terms conditions.
• Recipients should consult their GO regarding other potential prior approval waivers based on
project-specific circumstances.
• All costs charged to Federal awards must be consistent with Federal cost policy guidelines and
the terms of the award, except where specified in OMB Memorandum M-20-17.