Prior Approvals, Allowability of Costs, and Effort on Sponsored Projects

Updated 9/13/2020; 5:00pm - added FAQ #15 below related to subawardees and their pay continuity policies.

Updated 7/4/2020; 1:51pm - added 5 FAQs below related to salary and effort. FAQs no longer effective will be moved to the 'Superseded' section below.

When to contact your SPA Project Officer

While federal and private sponsors have been emphasizing flexibility around prior approval requirements and the allowability of costs on sponsored projects, you must still contact your SPA Project Officer to:

  • Notify the sponsor of a late progress report and/or final closeout documents (when the documents are submitted through SPA, such as NIH RPPRs);
  • Request a 1st or 2nd No Cost Extension;
  • Request carryover of NIH non-SNAP unobligated balances;
  • Request the transfer of any work to a new subrecipient;
  • Request the rebudgeting of participant support costs to other categories of expense;
  • Request a change of the named PI (or co-PI in NSF awards) to another PI;
  • Notify the sponsor of disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project by the approved PI/PD;
  • Discuss if any individuals relocated outside of the U.S. to conduct/continue work on a sponsored project (see FAQ#5 below); and
  • Any changes in scope.

List of sponsor-specific prior approval requirements

    The Council on Foundations issued A Call to Action: Philanthropy's Commitment During COVID-19, which includes a list of many private foundations pledging to be flexible during the COVID-19 public health crisis. In addition, see below a list of select sponsors' FAQs.

    The Council of Governmental Relations (COGR) has put together resources and a matrix of the different federal agency responses to COVID-19:

    FAQs

    Both federal and private sponsors have been emphasizing flexibility and the need for institutions to prioritize personnel safety and safety of research subjects.  See Sponsor List above.

    If the individual is working remotely and contributing to a sponsored project, then salary can be charged to that grant. 

    The usual grants management requirements apply.  If an individual cannot contribute to their current project but can contribute to another sponsored project, the salary must be moved to that funding source.

    For individuals who cannot perform their activities remotely, but are still not able to work on campus, salary transfers are required.  Specifically, where an individual’s effort on sponsored projects is significantly reduced because their ability to be on campus is materially constrained, an amount of salary commensurate with the individual’s reduced activity must be transferred from the sponsored project(s) to a non-sponsored source.

    Yes, the University’s temporary policy on pay continuity changed as of June 17, 2020, in response to changes in federal guidance.  The revised federal guidance added a significant restriction to the previous interim policy that had allowed salaries to be charged to grants even where individuals were unable to work because of COVID-19 disruption. Under the revised rules, Columbia is required “to exhaust other available funding sources to sustain its workforce and implement necessary steps to save overall operational costs (such as rent re-negotiations) during this pandemic period in order to preserve Federal funds for the ramp-up effort.” Our review, in conjunction with that of higher education associations, suggests that this requires using faculty discretionary funds and departmental and school resources before being able to charge pay continuation costs to sponsored awards. This new requirement to exhaust other resources, and the documentation required, presents significant risk to the research enterprise.  For this reason, the University, like many of our peers, will no longer afford itself of this pay continuity flexibility.

    The usual effort and salary principles apply.  You should make sure that the individuals’ salaries are charged to the projects on which they are working, in accordance with their effort. If they are, then no changes are needed.

    You should ask him to estimate, on average, the percent of a regular week that he is able to work. For example, if his estimate is that he is able to complete 80% of his regular week, then at least 20% of his salary should be charged to an unrestricted account.

    Going forward, no changes may be warranted to this individual’s salary allocation, but you should monitor regularly and adjust if the hours do not even out as expected. 

    However, for the period of June 17 to June 30, you should assess whether the person’s effort on sponsored projects was significantly reduced because their ability to be on campus was materially constrained.  If so, an amount of salary commensurate with the individual’s reduced activity must be transferred from the sponsored project(s) to a non-sponsored source.

    As is always the case, principal investigators are expected to monitor team members’ activity on research projects. For progress reports, applications for administrative supplements, and extensions, principal investigators should be able to describe the following:

    • Extra costs resulting from COVID-19 disruption
    • Impact of COVID-19 on project progress
    • Team members  who are unable to work remotely, and who therefore are on paid absence

    Documentation related to these items should be preserved.  At this time, there is no special format required, and many researchers may already be documenting this information in lab notebooks.  However, researchers may use this template COVID-19 Impact Tracker to keep general notes on the impact of COVID-19 on sponsored projects. 

    Finally, in the event that you have team members whose salaries are being charged to grants but who are unable to work remotely, please notify your SPA project officer to ensure any necessary sponsor notifications are made.

    No. The usual grants management requirements apply.  Grant funds allocated for a specific project may not be transferred to another project out of scope of the funded grant.  If you believe that you can change the scope of an existing project to respond to the COVID-19 public health emergency, please contact your SPA Project Officer to discuss obtaining approval from your funding agency.

    If prior approval is obtained, any repurposing of resources must be carefully documented.  In addition, the federal government has emphasized that researchers must not assume that additional funding will be available in the event of a shortfall.

    NIH is encouraging grant recipients wishing to work on COVID-19 research to apply for competitive supplements or other type of funding announcement as issued in their NIH Guide and in their COVID-19 page.  Our website contains a listing of several COVID-19 funding opportunities from various sponsors at https://research.columbia.edu/COVID-19_Research/Researchers/FundingOpps.

    Yes. Pursuant to Columbia's indirect cost rate agreement with the federal government, sick leave and other paid absences that are permitted under University policy may be charged to the grant.

    As a result of the COVID-19 pandemic, certain research activities that otherwise would have been performed on campus are being performed remotely.  In certain instances, researchers may have left the U.S. or are unable to travel to the U.S. and would like to start or continue working on a research project remotely.

    Working remotely from outside the U.S. may trigger sponsor approval/notification requirements and may raise additional issues that should be reviewed by the University.  These issues depend on several factors, including –

    • In which country the researcher will be located;
    • How long the researcher is expected to work remotely from outside the U.S.;
    • Which activities the researcher will be engaged in and whether the researcher will need access to certain export-controlled materials or non-publicly available 3rd party information while outside the U.S.;
    • Whether a new 3rd party will be involved in the research (e.g., will the researcher be using facilities at a local university?);
    • Whether additional funds will be required to complete the research;
    • Whether the sponsored research agreement restricts funding for research activities outside the U.S. or requires approval/ notification for research activities outside the U.S.

    In the event that you or a member of your research team (including faculty, postdocs, graduate students, or other research staff) plan to work remotely from outside the U.S., please notify your SPA project officer to determine if your sposnor needs to be notified. SPA will also work with Columbia’s Office of Research Compliance & Training and other offices as appropriate to address potential issues raised by remote work from abroad.

    For more information about working remotely, please see COVID-19 Research: Remote Work and Access to Research Data.

    Trip cancellation insurance is typically unallowable on grants. However, we are monitoring any additional guidance the federal government may issue related to travel. If you need to travel in the coming months to conduct business for a sponsored project, and you want to purchase trip cancellation insurance, you may reach out to your assigned SPA Project Officer to request prior approval from the sponsor to charge this cost to the grant.

    These types of expenses are considered administrative costs (indirect costs), and generally are not appropriate as a direct cost unless specifically approved by the sponsor. You may wish to talk with your supervisor about your needs in order to be set up to work from home.

    Yes, but you do not have unlimited flexibility. First, if you are in a job-specific or program-specific visa status, such as J-1, H-1B, E-3, TN, there are federal regulations governing which duties can be performed.  Please reach out to the institution that sponsors your visa for immigration guidance in advance. For those under Columbia's visa sponsorship it would be ISSO-Morningside/Manhattanville or ISSO-CUIMC.

    Second, under Columbia’s Guidelines for Incidental Career Development Activities for Postdoctoral Research Scientists, Scholars and Fellows, postdocs may engage in incidental career development activities (“PD Incidental Career Development Activity”) above and beyond their research activities.  The activity must be separate and distinct from the postdoc’s research. 

    Normally, such activity is limited to 10 hours a week, for no longer than one year.  However, during the COVID-19 public health emergency, the University is allowing postdocs to aggregate the amount of time available for an entire quarter, and use it all at once. 

    This means that postdocs who have availability because of the research ramp-down may dedicate up to 120 hours per quarter, with no weekly limit, to other Columbia projects that respond in some way to the COVID-19 public health emergency.  Such time would equate to, e.g., three 40-hour weeks or six 20-hour weeks.

    Postdocs must obtain their supervisors’ permission to take on such COVID-19 activity.  If they already spend part of their time on any other PD Incidental Career Development Activity, their effort dedicated to COVID-19 activity should be reduced accordingly so that the combined hours do not exceed the overall limit.  Finally, they must document the time spent on COVID-19 Incidental Career Development Activity to ensure that they do not exceed the 120-hour allotment per quarter.  This documentation is critical to the University’s ability to demonstrate that postdocs’ participation in these activities complies with University policy and federal regulations.  Postdocs may use this timesheet to document their time on COVID-19 Incidental Career Development Activity.

    For these purposes, unpaid activity is considered non-recurring, so the only approval required is that of the principal investigator.  Any compensated PD Incidental Career Development Activity must follow the usual approval process set forth in the Guidelines.

    If the nature of the work on the sponsored project required PPE prior to the COVID-19 pandemic (for example, hazmat, biohazards, infectious agents, etc.) then charging PPE to replenish these supplies is allowable as long as they are still necessary to advance the work on the project.

    If PPE was previously purchased by a sponsored project, was donated during COVID-19, and there is a need to replenish that PPE in order to advance the work on the project, then PPE can be re-purchased and charged to the sponsored project. Administrative supplement requests may be appropriate if there are not enough funds to re-purchase the PPE. However, administrative supplements are not guaranteed. Speak with your SPA Project Officer to discuss the specifics of such requests. It is important to maintain documentation of donated PPE. The COVID-19 Tracker is an example of how to maintain documentation.

    New sponsored projects with a need for PPE to initiate or advance work on a project (for example, new COVID-19 research, work with other infectious agents, etc.) can charge PPE supplies, if permissible by the sponsor.

    You cannot charge PPE to sponsored projects for general ramp-up and re-opening protections as required by the University, or for personal preference.

    If PPE charges are made to multiple sponsored projects or to a combination of sponsored projects and institutional funds, the costs must be proportionally allocated across all funding sources.

    Subawardees should follow their own internal policies regarding pay continuity.  Columbia PIs with sponsored projects containing subrecipients should continue to provide the requisite subrecipient monitoring, and stay in close communication with their subrecipients concerning the progress of their funded work. Any issues impacting the progress of their sponsored awards, such as pay continuation, or the work performed by their subawardees, should be properly documented.

    Archived FAQs

    This section contains previous FAQs no longer in effect.

    If the individual is working remotely and contributing to a sponsored project, then salary can be charged to that grant. 

    The usual grants management requirements apply.  If an individual cannot contribute to their current project but can contribute to another sponsored project, the salary must be moved to that funding source.

    If an individual is assigned to work remotely but cannot contribute to any university activity, the salary may currently continue to be charged to the award. This is allowable because the University’s current policy is to allow paid excused absences in this situation.  As circumstances unfold, the University will review this among other temporary policies, and communicate changes with the Columbia community.  

    Please note: NIH, NSF and the Department of Defense have issued explicit guidance regarding salary charges in this situation, but we await further guidance from some sponsors.  It is possible that some charges may need to be removed, based upon future sponsor guidance.

    The PI/lab must document and retain information on the staff and related compensation that is charged to any award when no contribution is made to the project.

    For effort certification purposes, and as is the case for any paid leave, the effort for this time period should be treated as time worked. See Effort Reporting FAQ 19.