OMB Issues Additional Guidance to Grant Recipients

As signaled as a possibility in its March 9, 2020 guidance in Memorandum M-20-11, the Office of Management and Budget issued Memorandum M-20-17 on March 19 to provide short term administrative, financial management and audit relief from the 2 CFR Part 200 Uniform Guidance requirements to a broader scope of recipients of grants and Federal financial assistance that are affected by the COVID-19 crisis.  Importantly, this OMB guidance authorizes awarding agencies to grant the administrative relief exceptions enumerated to the extent the awarding agency deems appropriate to recipients affected by the loss of operational capacity due to COVID-19.  Except as noted below, and until awarding agencies publish additional guidance on their implementation of Memorandum M-20-17, recipients must ask for relief, and the awarding agency then has the discretion to issue an exception to the requirements.