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​Manage COVID-19 Changes

With advance approval, you may charge salaries, wages and benefits to your 2019 LSTA grant as long as doing so is consistent with your organization's policy and it is for those who would normally not be spending this much time on this project.  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 grant as long as doing so is within the scope of the contract, is consistent with applicable Federal cost principles, and is to the benefit of the project.  Advance approval should be submitted on the Budget Revision Request form.

If you incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of your grant, or the pausing and restarting of grant-funded activities due to the public health emergency, you may, charge these costs to the grant 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).  Be sure to highlight these charges on your quarterly reports.

You should not assume that additional funds will be available should the charging of salaries, benefits, cancellation fees, 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 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.

It is best to avoid being in a situation where a deadline extension is requested.  When possible, instead of cancelling in-person events, assess if they can be conducted virtually. Having said that, there are many options for recuperating costs in the event they were no longer spent on expenses related to in-person activities.  Below are a few options to consider.

  • If you don't have the means to hold virtual convenings, funds could be used for technological infrastructure to support virtual events.

  • Funds could go toward more copies of books and connectivity materials for participants, maybe curriculum planning for ways to engage the community virtually, etc.

  • Hiring additional staff/interns/etc. to carry the load that these last-minute changes would bring are eligible expenditures.  Keep in mind, only work on the LSTA-funded project is an eligible expense.

Grants not fully expended will have an effect on your indirect cost.  Although we have received some COVID-19-related flexibilities, we have not seen flexibilities around indirect costs. In the absence of such flexibilities, grantees are only allowed to keep the portion of indirect costs that relates to actual spending on the grant.  The concept of indirect costs is that they are internal "expenses" the institution is granted to facilitate the spending of the total, so grantees are only entitled to that amount. 

The deadline to submit budget revisions has been extended to June 30, 2020.  You must have prior written approval for all budget revisions if the amount of money to be re-allocated is greater than 10% of the total award. The brief justification must include how CoVID-19 has disrupted your work.

If you have questions or concerns about carrying out your Pennsylvania LSTA-funded work, we ask that you reach out to your grant monitor or the LSTA office at as soon as possible.