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Information for IMLS Grant Applicants and Awardees

FAQs for IMLS Grant Applicants and Awardees with Questions about the Impact of COVID-19 on Their IMLS-Related Work

These frequently asked questions (FAQs) are meant to address general COVID-19-related questions associated with submitting applications to IMLS grant programs and managing existing IMLS awards. It reflects recent Office of Management and Budget (OMB) memoranda and IMLS governing authorities.

With memorandum OMB M-20-26 issued on June 18, 2020, OMB rescinded OMB M-20-17 and OMB M-20-20, and extended OMB M-20-17 salary and audit flexibilities with certain conditions. The FAQs below reflect these changes.

Because COVID-19 and associated complexities are evolving rapidly, we strongly encourage applicants and awardees to monitor this website regularly for updates.

APPLICANTS

1. Will IMLS change its grant application deadlines to help applicants adjust to new working conditions associated
with COVID-19?

We changed the application deadlines for five previously open library services grant programs. The extended deadlines for those applications have now passed.

We will continue to consider whether to change other application deadlines, and we will post any such changes as IMLS news releases, Coronavirus (COVID-19) Updates, and in Grants.gov.

[originally posted 4/6/2020; updated 7/17/2020]

2. We are considering submitting a proposal to IMLS for a future event or meeting. How should we take COVID-19 into account with conference planning and site selection?

Health and safety considerations of the participants should always be the foremost consideration in any proposal to IMLS. Since the COVID-19 situation is still evolving, it is important to consider flexibility and alternative plans in your proposal. For domestic travel, the Centers for Disease Control (CDC) offers guidance here. For foreign travel, please consult the State Department Travel Advisories website for up-to-date information.

[originally posted 4/6/2020]

3. What if my SAM registration expires on or after May 16, 2020?

Under OMB M-20-17, registrants in the System for Award Management (SAM) with active registrations expiring before May 16, 2020 were automatically granted a one-time extension of 60 days. You did not need to contact IMLS to request this extension.

Because OMB M-20-17 has been rescinded, SAM registrations expiring on or after May 16, 2020 are no longer automatically extended.

[originally posted 4/6/2020; updated 7/17/2020]

4. Are we allowed to charge costs to the award that are incurred before the award’s effective date?

For awards made through FY2020 IMLS CARES Act Grants for Museums and Libraries and IMLS CARES Act Grants for Native American/Native Hawaiian Museum and Library Services, you may charge pre-award costs that were incurred up to and including 90 calendar days prior to the date IMLS makes the award. Expenses more than 90 calendar days pre-award require prior IMLS approval.

Pre-award costs are those incurred prior to the effective date of the Federal award directly in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award.

Such costs must be consistent with Federal cost policy guidelines (for example, the Uniform Guidance in 2 CFR part 200), the scope and objective of the award, and the underlying appropriation. The costs must be reasonable and necessary to accomplish the award. The costs must appear in the budget submitted with your application. All costs incurred before IMLS makes the award are at your risk. IMLS is under no obligation to reimburse such costs if you do not receive an award or if the award is less than anticipated or inadequate to cover such costs. You should not assume that additional funds will be available should the charging of pre-award costs result in a shortage of funds to carry-out the award activities.

Please note that you 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 all pre-award costs. As with other grant recordkeeping, these records and cost documentation are subject to audit if you receive an award.

[originally posted 4/6/2020, updated 5/22/2020 and 7/17/2020]

AWARDEES AND COOPERATIVE AGREEMENT RECIPIENTS

IMLS understands that COVID-19 may impact your IMLS-funded project as activities are postponed or cancelled and access to your workspace is limited or denied. Please contact your IMLS program officer through eGMS Reach to explore normally allowable options such as modifying project activities, extending the performance period, minor budget revisions, and rescheduling report submissions as well as the salary and audit flexibilities provided by OMB M-20-26. We are committed to working with you to provide the maximum flexibility allowed by our governing authorities.

[originally posted 4/6/2020; updated 7/17/2020]

1. Will IMLS allow us to continue to charge salaries and benefits to our currently active award if we cannot perform the work specified in the award due to disruption caused by COVID-19?

With advance approval and until September 30, 2020, you may continue to charge salaries and benefits to your active IMLS award as long as doing so is consistent with your organization’s policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, both Federal and non-Federal.

You may also charge other costs necessary to resume activities supported by your IMLS award as long as doing so is within the scope of the original award, is consistent with applicable Federal cost principles, and is to the benefit of the project.

Under this flexibility, payroll costs paid with the Paycheck Protection Program (PPP) loans or any other Federal CARES Act programs must not also be charged to current Federal awards as it would result in the Federal government paying for the same expenditures twice.

Due to the limited funding resources under each federal award to achieve its specific public program goals, you must exhaust other available funding sources to sustain your workforce and implement necessary steps to save overall operational costs (such as rent renegotiations) during this pandemic period in order to preserve Federal funds for the ramp-up effort.

You should retain documentation of your efforts to exhaust other funding sources and reduce overall operational costs.

To request advance approval for charging salaries, benefits, or other costs as described above to your IMLS award, you must submit an Other Change request through your eGMS Reach account. In the field requesting an explanation for your request, enter “COVID-19: Salaries and benefits” or “COVID-19: Other costs.” Your supporting document should be formatted as a PDF, and it must include (1) a brief explanation of how COVID-19 has disrupted your work; (2) a description and dollar estimate of the expenses you wish to charge to your award; and (3) a verification that charging salaries and benefits to your active IMLS award is consistent with your organization’s policy of paying such expenses (under unexpected or extraordinary circumstances) from all funding sources, both Federal and non-Federal. We will notify you of the approval or rejection of your request through eGMS Reach or email.

You should not assume that additional funds will be available should the charging of salaries, benefits, and/or other costs necessary to resume activities result in a shortage of funds to eventually carry out the award activities.

Please note that you 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 activity costs related to interruption of operations or services. As with other grant recordkeeping, these records and cost documentation are subject to audit.

[originally posted 4/6/2020; updated 7/17/2020]

2. Will IMLS allow us to charge to our award costs associated with the cancellation of project events, travel, or other activities that were approved for our project?

Under OMB M-20-17, you had been allowed to charge cancellation costs to your award, with advance IMLS approval. With the OMB M-20-26 rescission of OMB M-20-17, that option is no longer available.

However, IMLS will still review requests to charge such costs on a limited case-by-case basis under non-OMB M-20-17 authority. To request advance approval for charging these costs to your IMLS award, you must submit an Other Change request through your eGMS Reach account. In the field requesting an explanation for your request, enter “COVID-19: Cancellation fees” or “COVID-19: Other costs.” Your supporting document should be formatted as a PDF, and it must include (1) a brief explanation of how COVID-19 has disrupted your work, and (2) a description and dollar estimate of the expenses you wish to charge to your award. We will notify you of the approval or rejection of your request through eGMS Reach or email.

You should not assume that additional funds will be available should the charging of cancellation fees or other costs result in a shortage of funds to eventually carry out the award activities.

If IMLS does approve your request, please note that such costs must follow 2 CFR § 200.403 (Factors affecting allowability of costs), 2 CFR § 200.404 (Reasonable costs), and 2 CFR § 200.405 (Allocable costs).

Please also note that you 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 cancellation or other fees related to COVID-19 interruption of operations or services. As with other grant recordkeeping, these records and cost documentation are subject to audit.

[originally posted 4/6/2020; updated 7/17/2020]

3. What if my SAM registration was expiring before May 16, 2020?

Under OMB M-20-17, registrants in the System for Award Management (SAM) with active registrations expiring before May 16, 2020 were automatically granted a one-time extension of 60 days. You did not need to contact IMLS to request this extension.

Because OMB M-20-17 has been rescinded, SAM registrations expiring on or after May 16, 2020 are no longer automatically extended.

[originally posted 4/6/2020; updated 7/17/2020]

4. Will IMLS allow no-cost extensions of ending awards?

Under OMB M-20-17, IMLS allowed no-cost extensions of awards that were active as of March 31, 2020 and scheduled to end prior or up to December 30, 2020 for a period of up to twelve (12) months. Project-specific financial and performance reports were to be due 90 days after the end date of the extension. With the OMB M-20-26 rescission of OMB M-20-17, that option is no longer available.

However, IMLS will still review requests for a no-cost extension on a case-by-case basis under non-OMB M-20-17 authority. To request approval for a no-cost extension, you must submit, at least 10 calendar days prior to the end of the period of performance specified in the award notice, an Extension to Award Period request through your eGMS Reach account. Your supporting document should be formatted as a PDF, and it must include (1) a brief explanation of how COVID-19 has disrupted your work, and (2) a revised Schedule of Completion showing how you will use the additional time to complete your project activities. We will notify you of the approval or rejection of your request and provide a revised Report Schedule through eGMS Reach or email.

[originally posted 4/6/2020; updated 7/17/2020]

5. Is IMLS extending the due dates for interim financial, performance, or other reporting because of COVID-19?

Under OMB M-20-17, IMLS allowed delays in submitting interim financial, performance, or other reports for up to three (3) months beyond their normal due date with advance approval. With the OMB M-20-26 rescission of OMB M-20-17, that option is no longer available.

However, IMLS will still review requests for an interim report extension on a case-by-case basis under non-OMB M-20-17 authority. To request approval for an extension of interim report due dates, you must submit an Other Change request through your eGMS Reach account. In the field requesting an explanation for your request, enter “COVID-19: Extend due date for reports.” Your supporting document should be formatted as a PDF, and it must include a brief explanation of how COVID-19 has disrupted your work. We will notify you of the approval or rejection of your request through eGMS Reach or email.

Please note that, as OMB M-20-17 was rescinded, if IMLS approves a report extension, you may not continue to draw down IMLS funds without the timely submission of the report.

[originally posted 4/6/2020; updated 7/17/2020]

6. What can we do if we are unable to submit our final reports on time due to COVID-19?

Under OMB M-20-17, IMLS allowed delays in submitting pending final financial, performance, and other reports required by the terms of the award for up to twelve (12) months beyond the normal due date with advance approval. With the OMB M-20-26 rescission of OMB M-20-17, that option is no longer available.

However, IMLS will still review requests for final report extensions on a case-by-case basis under non-OMB M-20-17 authority. To request approval for an extension of the due date for your final reports, you must submit an Other Change request through your eGMS Reach account. In the field requesting an explanation for your request, enter “COVID-19: Extend due date for reports.” Your supporting document should be formatted as a PDF, and it must include (1) a brief explanation of how COVID-19 has disrupted your work, and (2) the date by which you expect to submit your reports. We will notify you of the approval or rejection of your request through eGMS Reach or email.

[originally posted 4/6/2020; updated 7/17/2020]

7. What can we do if our indirect cost rate agreement expires or our negotiations for a new one are delayed because of COVID-19?

Under OMB M-20-17, IMLS allowed an extension on the use of your current approved indirect cost rates (i.e., predetermined, fixed, or provisional rates) for one additional year without submitting a new indirect cost proposal. With the OMB M-20-26 rescission of OMB M-20-17, this use extension option is no longer available.

[originally posted 4/6/2020; updated 7/17/2020]

8. Is IMLS allowing us to extend the deadline for our Single Audit submission?

If IMLS is your cognizant or oversight agency for audit and you, as an recipient or subrecipient, have not yet filed your single audits with the Federal Audit Clearinghouse as of March 19, 2020 that have normal due dates from March 30, 2020 through June 30, 2020, you may delay the completion and submission of your Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501 (Audit requirements), up to six (6) months beyond your normal due date.

Audits with normal due dates from July 31, 2020 through September 30, 2020 will have an extension of up to three (3) months beyond the normal due date.

IMLS does not require that you or your subrecipients seek approval for the extension from IMLS; however, you and your subrecipients should maintain documentation of the reason for your delayed filing.

If you or your subrecipients take advantage of this extension, you and your subrecipients would still qualify as a “low-risk auditee” under the criteria of 2 CFR § 200.520(a) (Criteria for a low-risk auditee).

Additionally, in order to provide adequate oversight of the COVID-19 Emergency Acts funding and programs, you and your subrecipients must separately identify the COVID-19 Emergency Acts expenditures on the Schedules of Expenditures of Federal Awards and audit report findings.

[originally posted 4/6/2020; updated 7/17/2020]

For other questions about active awards, please contact your IMLS program officer through your eGMS Reach account. Alternatively, you may send an email message to imls-museumgrants@imls.gov for museum awards or to imls-librarygrants@imls.gov for library awards, and we will make sure your message gets to the right person. We can do that most quickly if you include your award number in the subject line of the email.

These FAQs were most recently updated on July 17, 2020.