If we think about it, state and local governments are “the backbone of our public health system.” That’s how HHS Secretary, Alex Azar, put it in a recent funding announcement. This means states and local jurisdictions as well as tribal governments are on the frontlines when it comes to dealing with this global pandemic: Coronavirus or COVID-19. It’s also well-known that despite their importance, state and local governments are chronically underfunded, which puts additional stress on governments working to minimize spread of the virus.
So, how do governments proceed? This article will review the most recent funding announcements and guidance and how they can aid governments in their response efforts.
CDC Releases Funding to State and Local Entities to Fight Coronavirus
The first critical step to helping governments contain coronavirus is by aligning the necessary funds. The U.S. Department of Health and Human Services (HHS), through the Centers for Disease Control and Prevention (CDC) recently announced upcoming action to provide resources to a limited number of state and local jurisdictions to support the response to COVID-19.
Using funds provided to CDC through the HHS Secretary’s Transfer, CDC will:
- Award an initial $25 million cooperative agreement to states and local jurisdictions with the largest burden of response and preparedness activities. This is an initial award for those who require immediate assistance for activities including monitoring travelers, data management, shipping, infection control, surge staffing, etc.
- Award an initial $10 million cooperative agreement to state and local jurisdictions to start coronavirus surveillance across the U.S. This initial award is also for a limited number of jurisdictions.
It’s important to keep in mind that while a grant is intended to provide assistance, there is generally little involvement from the awarding agency. However, these cooperative agreements will have substantially more involvement from the grantor.
OMB Working to Provide Administrative Relief for COVID-19 Response
Anyone in the funding world knows that applying for federal grants is a time-consuming process, and if we have learned anything from the rapid spread of COVID-19, it’s that time is of the essence. To ease the administrative burden on public-sector organizations seeking to apply for federal assistance, OMB has released a March 9 Executive Memorandum which allows federal agencies to grant class exceptions to those requiring the resources to respond to coronavirus outbreaks.
These exceptions are available for a limited time and only apply to awards that support activities, i.e. research and services, related to COVID-19 emergency response. The exceptions include:
Flexibility with SAM registration/recertification for applicants: Applicants do not have to be registered at the time of application, but they must be registered at time of award.
Waiver for NOFOs Publication: Agencies can shorten the amount of time a Notice of Funding Opportunity (NOFO) is published (less than 30 days).
Pre-award costs: Awarding agencies may allow pre-award costs incurred from January 20, 2020 through the Public Health Emergency Period (90 days) and prior to the effective date of award.
No-cost extensions on expiring awards: Awards that were still active as of March 31, 2020 and scheduled to expire before or on December 31, 2020, may receive an automatic 12 month no-cost extension.
Abbreviated non-competitive continuation requests: Non-competitive continuation grants requests required between April 1, 2020 and December 31, 2020 may only require a brief statement verifying they are able to resume/restore their project activities and accept the continuation award.
Expenditure of award funds for salaries and other project activities: Expenditures for salaries and other project activities may be allowed to continue while other costs can be charged to the award if necessary to resume project activities. Awarding agencies will post more guidance.
Waivers from prior approval requirements: Prior approval requirements may be waived to allow the recipient to address the response more effectively. However, costs must remain consistent with the cost principles and guidelines (unless waived by this memorandum).
Exemption of certain procurement requirements: Procurement requirements under 2 CFR 200.319(b) for geographic location and 2 CFR 200.321 for small and minority businesses may be waived.
Extension of financial and other reporting: Recipients may be allowed an additional three months to submit their finance and other reports. Drawdowns will not be interrupted if the delay is allowed by the awarding agency.
Extension of Single Audit submission: Recipients may receive a 12-month delay approval to submit their Single Audit report. This delay will still qualify the grant recipient as a “low-risk auditee.”
Remember, this EM only affects the federal agencies who are directly related to the research and services necessary to carry out the emergency response related to COVID-19. These exceptions do not apply to all federal awards. If there is any reason to extend these exceptions to other agencies, the Administration will make that call and send out notice accordingly.
Ultimately, while the federal government is taking the necessary steps to ensure funding is in place and a public health emergency is declared, the real action lies with the state and local governments. By knowing what grants and resources are available and how to expedite getting those resources, governments can accelerate efforts to keep their communities safe, while advancing our nation's response against coronavirus.
In part two of this series, we’ll discuss three important steps state, local, and tribal governments can take to act fast against coronavirus and maximize available resources to help their communities.
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