Weekly COVID-19 Update: OMB Memorandum, Human Subjects Research and More
07/08/2020, 02:35:01 PM
From the Vice President for Research at the University of Houston. View this message in browser.
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Dear Research Faculty,​​

To protect the health and safety of all Texans in view of the increase in COVID-19 cases, Governor Abbott issued last week the Executive Order GA-29 that requires the wearing of face coverings in all counties in Texas that have more than 20 positive COVID-19 cases. He also issued a proclamation that amended the previous Executive Order GA-29 relating to mass gatherings in Texas, which limits gatherings of people to no larger than ten and requires social distancing from those not in their group. We need to take some additional measures to reduce the risk of infection in human subjects research. I will first address the June 18 OMB Memorandum that has a number of implications on how federal research funds that are affected by COVID-19 can be used.

OMB Memorandum M-20-26

In my June 25 letter, I addressed the June 18 OMB Memorandum M-20-26Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations. In that email, I mentioned that until September 30, federal agencies can continue to allow charging salaries to active grants for employees who are unable to work due to COVID-19. Most federal agencies adopted this policy, and we list the agencies on our Additional Resources page. Please talk to your departmental grant manager if you have employees on your grants who are using any COVID-19 leave options to ensure that salaries are appropriately charged.

The new memorandum has additional requirements that I would like to alert you to:

(1) If you had to pause your research on an active grant due to COVID-19 but continue to charge payroll on your award, the agency may evaluate your ability to resume the project activity in the future and the appropriateness of future funding. You need to make sure that funds for non-payroll activities will remain available to accomplish the goals of the award and are not diverted to payroll. Once the award has exhausted the personnel budget, you may have to use other funding sources, such as IDC or residual funds, to cover the cost of salaries and benefits to ensure that sufficient funds are available to resume the work on the project in the future.

(2) Institutions are asked to implement steps to reduce overall operational costs during this pandemic period in order to preserve federal funds as we ramp up our research efforts. Hiring freezes and salary reductions are examples of such cost reduction measures. The federal government asks recipients specifically to exhaust other available funding sources first before charging salaries and benefits of those who are unable to work to active awards. Efforts to exhaust other funds must be documented. To give you an example, faculty salary that is charged on a paused grant should revert to the departmental funding source.

(3) Payroll costs that are covered by other programs, such as the Paycheck Protection Program (PPP) and the Federal CARES Act programs, must not also be charged to current federal awards as this would constitute the federal government paying twice for the same cost.

(4) A number of flexibilities that were provided in the now rescinded memoranda M-20-17 and M-20-18 are no longer available:  

  1. Automatic no-cost extensions 
  2. Costs related to the cancellation of events, travel or other activities necessary for the performance of the award
  3. Waiving of prior approval for items needed to respond to COVID-19 effectively
  4. Automatic approval for a request to delay the submission of progress, financial and other reports
  5. Automatic approval for a request to delay award closeout

We will address this memorandum in the next Virtual Office Hours and will try to answer any additional questions about this (AVPR Neuhauser will respond during the Virtual Office Hours).

Human Subjects Research Restrictions

I mentioned in my June 9 email that we started to develop guidelines to relax some of the COVID-19-related restrictions that we had imposed on human subjects research. Since the Harris County Threat Level is at its highest now, we will need to pause our current plan to open human subjects research further to protocols that would require contact between subjects and researchers closer than six feet. For the duration of Harris County Threat Level 1, in addition to the other guidelines we list on our Human Subjects page, we are restricting human subjects research as follows:

  • On campus, in settings that do not provide paid clinical health care services: The only research procedures that can be conducted are those that can be done while maintaining at least six feet of distance at all times.
  • On or off campus, in settings that do provide paid clinical health care services: All approved research procedures may be conducted in these settings, following established clinical policies and procedures (in particular, sanitization procedures and PPE utilized for COVID-19 in the specific clinical field).
  • Off campus in other established institutional settings (e.g., schools, prisons): The only research procedures that can be conducted are those that can be done while maintaining at least six feet of distance at all times. In addition to UH requirements, additional precautions set forth by the external institution apply.
  • Off campus in non-institutional/community settings (e.g., homeless shelters or on the streets, farmers markets, or community social/church gatherings): No human subjects research is allowed at this time.

We are updating our Human Subjects page with additional guidelines and a set of questions that should help researchers assess and minimize risk.

VPR Virtual Office Hours

The next VPR Virtual Office Hours will be on Friday, July 10, at noon (please note the time). You will be able to access the event through the Research & Innovation Teams site. I hope you will be able to join us next week.

Best regards,

Amr Elnashai, FREng  
Vice President for Research and Technology Transfer

Amr Elnashai | VP for Research and Technology Transfer | elnashai@uh.edu | 713-743-4736

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