Memorandum
To: Financial Assistance Communication
Liaisons and Nominated Financial
Assistance
Communications Liaisons
From: Debra E. Sonderman, Director, Office of Acquisition and Property
Management /signed Debra E. Sonderman
Subject: Administrative Relief Options for
Recipients Impacted by Hurricanes Katrina and Rita
The Office of
Management and Budget (OMB) issued a memorandum on September 30, 2005, identifying
a number of ways in which federal grant-making agencies could
relieve, in the short term and, at their discretion, certain administrative and
financial management requirements under the OMB grant circulars (A-21, A-87, A-102,
A-110, A-122), for those recipients located in a county or parish where a major disaster has been
declared under the Stafford Act as a result of Hurricanes Katrina and Rita.
The attached
listing of proposed relief measures is provided for your information. Decisions
to implement any of these actions are entirely at the discretion of the
bureau\office\program. However, please note that implementation of the actions
in no way releases the Department of the Interior bureau\office\program from
fulfilling all required grantor administrative actions (i.e.,
creation\execution of amendments, F AADS reporting, etc.). Again, these actions
may only be implemented on behalf of those recipients located in a county or
parish where a major disaster has been declared under the Stafford Act as a
result of Hurricanes Katrina and Rita.
Bureaus\Offices\Programs
implementing any of these actions are urged to post information prominently on
applicable web sites. Bureaus must maintain records of all programs that
implement any of these actions for possible future review. These records shall
identify, at a minimum, the name of the Hurricane, award number, recipient's
name, type of action taken, program\Catalog of Federal Domestic Assistance
(CFDA) number, and action date.
If you have
questions regarding this requirement please contact Kate Oliver of my staff at
202/208-3345.
Administrative Relief
Options for Recipients Impacted by Hurricanes Katrina and
Rita
The following
actions involving financial assistance administrative provisions may be taken
if deemed necessary by the bureau\office\program for those recipients located
in an identified county or parish where a major disaster has been declared
under the Stafford Act as a result of Hurricanes Katrina and Rita:
Flexibility with application deadlines
Bureaus\Offices\Programs
may provide flexibility with regard to the submission of competing applications
in response to specific announcements, as well as unsolicited applications.
Specific guidance should be provided, if appropriate, on any applicable web
sites.
No-cost extensions on expiring awards
To the extent
permitted by law, awards that were active as of
Abbreviated continuation requests
In cases
where continuation requests from projects with planned future support were scheduled for receipt during
Expenditure of award funds for salaries and other project
activities
Bureaus\Offices\Programs
may allow recipients to continue to charge salaries and benefits to currently
active Federal awards consistent with the recipient organization's policy
regarding paying salaries (under unexpected or extraordinary circumstances)
from all funding sources, Federal and non-Federal. Other costs charged to
Federal awards, including those necessary to resume activities supported by the
award, may also be allowed by
bureaus\offices\programs, consistent with applicable Federal cost principles
and the benefit to the project. Bureaus\Offices\Programs may also evaluate the
grantees ability to resume the project activity in the future and the
appropriateness of future funding, as done under normal circumstances-based on
subsequent progress reports and other communications with the recipient.
Prior approval requirement waivers
Requirements
for prior approval for the re-budgeting of funds within the scope of the
project may be waived, and automatic carryover of unspent balances may be
granted for currently active awards awarded prior to
Extension of financial and other reporting
Bureaus\Offices\Programs
may grant a delay of up to three (3) months beyond the original due date for submission of Federal cash transaction reports
on currently active award accounts. If this delay is allowed, recipients will
continue to draw down Federal funds without the timely submission of these
reports, however, these reports must be submitted at the end of the postponed
period. Extensions granted for other financial and administrative reports, such
as the property and invention reports, should be reviewed on a case by case
basis by the bureau\office\program.
Extension of currently approved indirect cost rates
Recipients
may be allowed to continue to use the currently approved indirect cost rates
(i.e., predetermined, fixed, or provisional rates) to recover their indirect
costs on Federal awards if approved by the bureau\office\program. The use of
current rates may continue for one additional year without submission of an
indirect cost proposal in these cases. Recipient requests for an extension of
the indirect cost rate proposal submission to finalize the current rates and
establish future rates may also be granted.
Extension of closeout
Bureaus\Offices\Programs
may approve recipient requests to delay submission of any pending financial,
performance and other reports required by the terms of the award for the
closeout of expired projects, providing that proper notice about the reporting
delay is given by the recipient to the government. This delay in submitting
closeout reports may not exceed one year after the award expires.
Alternatives for record retention and cost documentation
Recipients
should be allowed to substitute copies of original records for the original
records, as permitted under OMB Circular A-110. In helping recipients to
reconstruct the supporting project documentation, bureaus\offices\programs
should provide copies of all needed records that they maintained, such as
indirect cost proposals, cost allocation plans, and past financial status
reports.