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Important Information for Historic Preservation Fund Grantees and Subawardees & Contractors Working on Grant-Assisted Projects
The 2019 novel coronavirus (COVID-19) is changing the way we all work and live for at least the next several months. Our priority is for all our grantees, staff, partners, and contractors to stay safe. This page centralizes guidance on how to handle your Historic Preservation Fund grant during this time of uncertainty. Key information regarding public health updates, data from the Centers for Disease Control and Prevention (CDC), the Federal Emergency Management Agency (FEMA), and the Office of Management and Budget (OMB) may be found by following the links at right.
Key questions at this time seem to center around needed extensions, can staff/personnel be paid, how to handle contract changes, etc. Below please find frequently asked questions and answers those questions. We understand if your project needs to be put on hold or extended, or you may need to modify your scope of work and budget to reflect changes due to the virus. This can all happen; we have the authority to make these changes; we have the authority per Office of Management and Budget (OMB) to make these changes through June 19, 2020.
National Park Service guidance implements specific administrative relief authorized by the Office of Management and Budget (OMB) Memorandum M-20-17, “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations”, dated March 19, 2020. This guidance supplements the OMB guidance and is only applicable as long as the OMB M-20-17 is in effect. OMB provided short-term relief of certain Title 2 Code of Federal Regulation (CFR) requirements without compromising accountability. Per OMB, these flexibilities are time limited. OMB will reassess their applicability by June 17, 2020. The NPS will update this guidance over time as needed to reflect current OMB guidance and to provide answers to frequently asked questions we receive related to this guidance.
|Office of Management and Budget Memorandum||Status|
|M-20-17||In general, rescinded; see note below.|
|M-20-11||Expired July 26, 2020.|
|M-20-26||Extends specific parts of M-20-17.
Allowability of Salaries and Other Project Activities (Item 6 of M-20-17) extended to September 30, 2020, but with restrictions. See Appendix A of M-20-26.
Extension of Single Audit Submission and COVID-19 Emergency Acts Fund Reporting (Item 13 of M-20-17) extended to December 31, 2020 with the following notes: audits due March - June 2020 have a 6-month extension; audits due July - September 2020 have a 3-month extension.
Status of State, Tribal, Local, Plans & Grants Division OfficeCurrently, the State, Tribal, Local, Plans & Grants (STLPG) division of the National Park Service is on mandatory telework, but we are just as available to you as we were before. Please reach out to your grant manager, e-mail us your main questions, or call us at 202-354-2020, and we will respond quickly as we normally do. We ask that you do not send physical mail as we are unable to retrieve it, and instead send us as much information digitally as you can. We have tools that can assist with this, like sending large files via our FTP service, etc. Just ask.
Other Important InformationThe National Park Service changed in financial systems in October 2020. The December 2020 timeline transition away from Dun & Bradstreet Data Universal Numbering System® (DUNS) number to a Unique Entity Identifier (UEI) is delayed. No information is currently available on when the UEI transition will occur.
There has been no change (and there will be no change) to the systems that you use like ASAP, SAM.gov, or Grants.gov. They are still active, running, and staffed.
Information for Subawardees and Contractors Working on Projects Supported by the Historic Preservation FundSubawardees and contractors are organizations or individuals that have received funding from a prime recipient. Prime recipients have received an award of financial assistance directly from the National Park Service. Guidance on this page is for prime recipients; subawardees (also called subgrantees) and contractors will need to work with their prime recipients on any COVID-19 related changes.
Conferences, Trainings, and Events that are part of our grant have been cancelled, what do we do?NPS has the authority due to the COVID-19 to extend and amend grant agreements up to one year from the current end date. We don’t want to abuse this authority, so it must apply to issues caused by our new life of quarantine. Please contact your NPS grant manager with an email identifying your grant number, requesting an extension or modification, and providing specific reasons related to the virus. Give a realistic date that you will able to complete all subgrant/contract(s), knowing we cannot extend more than one year. This will also give you the extensions and approvals you need to reassure subgrantees, etc. Currently we only have OMB authority to process these extensions until June 19, 2020, unless that authority is extended.
We incurred costs for the event we cancelled, can the grant cover those?Costs that cannot be refunded due 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 can still be covered. Please notify your grant manager if you are encountering these types of costs. There will not be additional funding available to make up for these lost expenses.
Staff has been sent home; can we fund their salaries? What about our consultant?Follow your organization's administrative emergency personnel policies. Grantees may continue to charge salaries and benefits to active Federal awards consistent with their policy (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. If your policy is clear that personnel will be sent home on administrative leave and not be allowed to work then yes, HPF can still cover their salaries. If your policy is personnel must telework or take leave (like NPS) then HPF can still cover their salaries or leave. If you do not currently have a policy, you may create one and back date to March 19, 2020, when OMB granted this authority. The key is that federal and nonfederal funding must be treated the same. The same rules apply to any match.
If a consultant/contractor is not able to work, they cannot be paid by HPF, but an extension could be granted or scope of work adapted. If they can continue to work, or you can adjust the work so it could be done in a telework situation, then HPF can still pay. We have been strongly encouraged to be as accommodating as possible to ensure those contracted for work can continue working, so please think creatively about how that can happen, and discuss with your grant manager.
Our office is closed, how do we submit our interim or closeout worksheets?Guidance from OMB allows the NPS to grant extensions and allow you to continue the work on the project or receive more time for closeout reporting. You must request this extension by email from the NPS, including your grant number and virus-related reason for the extension. For interim reports you will be allowed up to ninety (90) days to submit, for closeouts one year. Again, to submit these, email us. This authority currently lasts through June 19, 2020.
Can activities we planned for 2020 be adjusted?Yes, you can change the scope of work, and budget for your grant funding should be affected by the virus. As long as you are meeting the intent of your grant application then we have some flexibility. Please talk with your NPS grant manager about any major shifts that you need to make because more than 10% of any line in your SF 424A budget (personnel, fringe, travel, supplies, equipment, contracts, indirect, etc.) needs an approved modification. We can help you with this, email us and set up a time to talk, before June 19, 2020.
Our indirect cost rate is about to expire, can we still charge it?COVID-19 guidance from OMB allows NPS to approve requests for an extension on the use of expired rates for one additional year without submission of a new indirect cost rate. Please see the posted guidance.
We will be delayed submitting our single audit, what should we do?COVID-19 guidance from OMB allows recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse and have fiscal year-ends through June 30, 2020, to delay the completion and submission of the Single Audit reporting package to six (6) months beyond the normal due date. You should keep record of the reason for the delay in submission for your file. Please see the posted guidance.
What if we cannot access a real signature?NPS will accept digital signatures, especially during this time. If you are having trouble signing, please let us know, this is something we can work with you on to ensure it does not hold up your grant work.
What is a Subaward or Subrecipient?As described in 2 CFR 200.92 and 93:
Subaward means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.
Subrecipient means a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency.
What is a Contract?As described in 2 CFR 200.22 and 23:
Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award. The term as used in this part does not include a legal instrument, even if the non-Federal entity considers it a contract, when the substance of the transaction meets the definition of a Federal award or subaward (see §200.92 Subaward).
Contractor means an entity that receives a contract as defined in §200.22 Contract.
Last updated: March 15, 2021