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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

This notice is meant to address general COVID-19-related questions associated with submitting applications to IMLS grant programs and managing existing IMLS awards. It reflects both the Office of Management and Budget 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,” and IMLS governing authorities. IMLS is providing this information as a service to our applicant and awardee communities. 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 have changed the application deadlines for five open library services grant programs. You can read the news release on the new deadlines here.

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.

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.

3. What if my SAM registration is expiring soon?

Current registrants in the System for Award Management (SAM) with active registrations expiring before May 16, 2020 have been automatically granted a one-time extension of 60 days. You do not need to contact IMLS to request this extension.

For other questions about submitting new applications, please contact an IMLS program staff member listed on the landing page for the grant program. Find a list of our grant programs and links to landing pages here.

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

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 C.F.R. 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.

[added 5/22/20]

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 flexibilities provided by OMB Memorandum M-20-17. We are committed to working with you to provide the maximum flexibility allowed by our governing authorities.

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, 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.

If you suspend project activities temporarily due to the impact of COVID-19, 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.

To request advance approval for charging salaries, benefits, or other costs as described above to your IMLS discretionary 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 COVID-19 interruption of operations or services. As with other grant recordkeeping, these records and cost documentation are subject to audit.

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?

If you incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of your award, or the pausing and restarting of grant-funded activities due to the public health emergency, you may, with advance approval, charge these costs to the 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).

To request advance approval for charging these costs to your discretionary 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.

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 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.

3. What if my SAM registration is expiring soon?

Current registrants in the System for Award Management (SAM) with active registrations expiring before May 16, 2020 have been automatically granted a one-time extension of 60 days. You do not need to contact IMLS to request this extension.

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

To the extent allowable by law, including but not limited to the GONE Act of 2016, IMLS will allow 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 will be due 90 days after the end date of the extension.

To request approval for a no-cost extension, you must submit 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.

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

IMLS may allow delays in submitting interim financial, performance, or other reports for up to three (3) months beyond their normal due date with advance approval.

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.

If we approve the extension, you may continue to draw down IMLS funds without the timely submission of these reports. However, you must submit the reports at the end of the postponed period.

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

IMLS may allow delays in submitting any 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.

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.

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?

If your agreement expires soon, you may request 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. 

If your negotiations for a new rate are delayed, you may request an extension on the use of your indirect cost rate proposal submission for up to a year in order to finalize your current rates and establish future rates.

To request approval for an extension on the use of your current approved indirect cost rate agreement or your indirect cost rate proposal submission, 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 indirect cost rate agreement.” 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.

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, and you have a fiscal year-end 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), to six (6) months beyond your normal due date.

IMLS does not require that you or your subrecipients seek approval for an extension from IMLS; however, you and your subrecipients should retain 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).

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.