Q. Are there guidelines for paying graduate students, postdocs and technical staff off of grant?
A. Yes. As we work through this challenging time, we ask that you follow the following guidelines for continuing to support personnel, particularly graduate research assistants, technical staff, and postdoctoral fellows on sponsored projects. The bullet points are listed in preferential order and to the extent possible the majority of personnel should have tasks assigned that fall into the first category.
Personnel temporarily unable to perform on a sponsored project in the typical manner because of campus closure can still be supported in accordance with their previously established allocation of effort as long as alternate work related to the project can continue. You must contact the research office at coronavirus_RO@mail.wvu.edu before removing personnel from financial support.
Guidance for charging salaries and stipends to grants and contracts in order of preferred utilization:
- Those personnel working remotely and contributing to the project in the usual manner or in an alternative manner that still aligns with project objectives can remain supported by the project.
- Personnel who cannot contribute to their current project, but who can contribute to another sponsored project or school activity should have their salary moved to the other funding source.
- Perosnnel prevented from contributing to their current project due to illness or quarantine can remain supported by the project for up to 75 hours in proportion to their previously established allocation of effort. This is consistent with WVU Emergency Leave Policy.
- Approval from the sponsor may be required if a temporary work stoppage will result in missed deliverables, a change in the scope of work, a change in key personnel. Sponsor approval may also be required if the Principal Investigator or other personnel must disengage from the project for more than three months and/or reduce their total effort by 25 percent or more. Use of this category will require assistance from the Office of Sponsored Programs via a request to coronavirus_RO@mail.wvu.edu.
Q. What about research activity?
Q. Does Dr. King’s memo to shut down all on campus labs apply to social scientists?
A. Yes – the directive to shut down research labs to only maintenance mode applies to social science labs as well.
Q. I need access to my data to continue working on it – can I take a copy home?
A. You may remove de-identified data files from your lab as de-identified data is not considered human subject research. The definition of de-identified is that the file does NOT contain any of the 18 HIPAA identifiers. The 18 identifiers are:
- Dates, except year
- Telephone numbers
- Geographic data
- FAX numbers
- Social Security numbers
- Email addresses
- Medical record numbers
- Account numbers
- Health plan beneficiary numbers
- Certificate/license numbers
- Vehicle identifiers and serial numbers including license plates
- Web URLs
- Device identifiers and serial numbers
- Internet protocol addresses
- Full face photos and comparable images
- Biometric identifiers (i.e. retinal scan, fingerprints)
- Any unique identifying number or code
Faculty should review any files that are removed from their labs and provide approval by email for said removal, if to graduate students or post-docs.
Q. I am planning on moving my data collection from in-person to another format – is there anything I need to know?
A. As per the March 13th memo:
Submit study changes (e.g., to alter the mode of data collection, protect participants/study personnel, etc.) by adding “COVID” as the first word to the study title in WVU+kc. Using “COVID” will flag submissions for faster review. If an investigator needs to make a change to research plans in order to eliminate apparent immediate hazards to participants, changes can be made and then reported to the sponsor and to the IRB within 5 days. Examples include mitigation of potential exposure or a need to provide medically necessary care (including study drug) to participants in isolation or quarantine because of exposure. Consider submitting a continuing review in lieu of an amendment. WVU IRB encourages sponsors and investigators to take steps to eliminate additional risks to participants and personnel.
Also, please be sure that data collected online do not contain IP addresses.
Q. My in-person data collection takes place off campus – can I still collect that data?
A. No – you may not collect any in-person data, no matter the location, until further notice or unless you have a specific exemption from VPR King. Please contact coronavirus_RO@mail.wvu.edu if you would like to discuss on exemption for extraordinary circumstances.
Q. Where can I get information about the latest updates from the federal agencies about proposals and awards?
A. The Council on Government Relations (COGR) is operating a website that keeps up-to-date information.
Q. I am self-isolated, quarantined, and/or at home caring for a sick family member and am unable to submit my grant by the stated deadline. May I request an extension?
A. Most federal agencies do not grant prior approval for late submissions; however, there are existing policies that address extenuating circumstances. Check the links at COGR for the most contemporary information. We also strongly encourage you to discuss your specific situation with both your agency Program Official and OSP.
Q. Is there federal research funding available to study COVID-19?
A. Yes, see the following:
Q. What are options for research sponsored employees to work remotely?
A. Literature searches, data analysis, paper writing, development of presentations and advance planning for new experiments are all work that can be conducted remotely.
Q. Are research laboratories and facilities still open and operational?
A. Unfortunately, they are not, with the exception of basic maintenance of equipment, cell lines/animals. Written waivers to allow continuity of research that would otherwise jeopardize unprotectable data or samples should be requested from VPR Fred King. Waivers will not be granted merely to maintain on-site research productivity
Q. Can I go into my lab to check on things?
A. Yes. You can go in. The hibernation is intended to ramp research down to the absolute minimum just to maintain experiments and on-site research, so that they can be ramped up again within minimal difficulty when the situation is resolved.
Q. How long will this restriction last?
A. It's very difficult to say, but you should expect that suspended lab access will likely last at least four to six weeks. We will update you if this estimate changes based based on the local and national situation.
Q. I am a principal investigator working remotely from home during self-isolation. Can my effort still be charged to my federal grant?
A. Yes, provided you remain engaged in your project.
Q. I am a principal investigator and I am (or some of my staff/students) are required to work from home. Can I charge supplies relating to telework (i.e., such as a laptop, printer, office supplies, etc.) to my grant?
A. In general no. These types of expenses are considered administrative costs (indirect costs), and generally are not appropriate as a direct cost unless specifically approved by the sponsor. A reduction in operations does not change this fact. There are some allowable expenses related to telework such as additional software licenses, instrumentation to check on laboratory conditions (remote temperate sensors) etc. As a rule of thumb, if you wouldn’t bill it to your grant before, you probably can’t now
Q. What if I am a 12 month employee on sponsored research funding who is home sick and can't work on my project? Can my salary still be charged to the grant?
A. Yes. Pursuant to WVU’s indirect cost rate agreement with the federal government, sick leave and other paid absences that are permitted under University policy may be charged to the grant.
Q. The COVID-19 situation will impact my graduate research and/or dissertation. What should I do?
A. We will work to mitigate any challenges that the COVID-19 situation creates in completing research projects and/or dissertations on time. We encourage open communication to ensure agreement about procedures for graduate student researchers in each lab. We ask all faculty to work with students to accommodate their particular situations, while helping each student continue their research path under the current circumstances.
Q. Will the Department of Environment, Health & Safety be available if needed?
A. Yes, that hasn’t changed. The number during regular business hours is 304-293-3792 and for after hours call the University Police 24/7 Communications Center 304-293-3136. You can also submit an EHS Service Request Form.
Q. Who do I call if I come into the lab or office and there’s an emergency (water leak, fume hood problem etc.)?
A. That hasn’t changed, it’s still Facilities. If your request is an emergency or items that need immediate response (i.e., breaker tripped, broken water pipe, etc.), please call the Help Line at 304-293-4357 (HELP).
Q. What is the contingency plan for research animal care?
A. WVU has significant advance planning for animal care. Please contact firstname.lastname@example.org with any concerns. Researchers should anticipate some disruption in staffing for research work and consider this impact on the long-term recovery of animals from procedures. Support of research efforts by university resources will be available but limited. The primary focus in all planning must be personnel safety while working to ensure continued animal care and humane treatment of research animals.
In particular groups should:
- proactively reduce or suspend breeding of animals and assume a reduced laboratory workforce.
- always have an abundant supply of necessary supplies on hand and realize that core facilities and other resources may not be available.
- realize that facility and equipment repairs, calibrations, and certifications may be delayed.
- disinfect workspaces
- realize that collaborators at other institutions (domestic or foreign) may be similarly impacted and unable to participate in the project.
- post emergency contact numbers in an easily accessible area and rovide updated information to IACUC and Office of Laboratory Animal Welfare.
- Ensure staff have a copy of emergency contact numbers at home
- Ensure that emergency services can gain access to all areas where animals are housed
- If a group needs APPROVAL OF AMENDMENTS AND PROTOCOLS, researchers should contact the Office of Animal Welfare.
Q. Are travel cancellation costs due to COVID-19 allowable as direct charges to sponsored projects?
A. Specific federal guidance on this topic is evolving. The individual's first priority should be to work with the airline and/or hotel, as many are waiving change fees or are offering full refunds for trips that you wish to change. Because the federal regulations explicitly direct us to follow our institutional policies and because we are expected to have consistent treatment across all fund sources, we suspect it is likely that sponsors will allow reasonable cancellation costs as direct charges to grants and contracts in this set of circumstances.
In order to be allowable, it is reasonable to assume that the traveler has requested and been denied a refund, and that documentation of such a request is retained in the department. But, since direction has not yet been provided by many federal agencies, departments should track COVID-19 related charges or credits on sponsored projects in case federal agency guidance requires a change to be made.
Q. Can I charge trip cancellation insurance to my grant?
A. Trip cancellation insurance is typically unallowable on grants. However, we are monitoring any additional guidance the federal government may issue related to travel. If you need to travel in the coming months to conduct business for a sponsored project, and you want to purchase trip cancellation insurance, you may reach out to OSP to request prior approval from the sponsor to charge this cost to the grant.
Q. I am a PI on a grant, which includes hosting a conference with many collaborators participating from around the world. I have already incurred expenses for the rental space at the convention center. I am working with the venue to get a credit but there will be a sizeable cancellation or penalty fee. Can I charge this to my award? And can I pay the travel fees and any associated costs for the hundreds of collaborations that were planning on attending?
A. If the PI (organizer) believes it would be unwise to hold the conference or it is not permissible by university policy and/or CDC guidelines, the organizer should confer with his or her program officer and grants management specialist to decide whether to cancel the meeting, postpone the meeting, or convert the meeting to an on-line format.
If the request is made verbally, written documentation of the decision should follow (an email from the sponsor to the PI and OSP should be sufficient). At many federal agencies, the program officer cannot independently make this type of decision, and grants office concurrence is required. PIs should follow the requirements for their specific sponsor.
Organizers may wish to make a firm decision about keeping or cancelling a meeting early enough to enable their participants to take advantage of discounts offered by airlines or hotels related to COVID-19 changes or early cancellation (particularly for hotels). In addition, a decision by the organizer to cancel the conference may assist some participants in convincing their institution to pay their cancellation costs.
If approved by the sponsor, once cancelled, the non-refundable costs for the venue would be an allowable charge to the project (if the project was scheduled to incur those costs in the first place). In general, the costs for participants should follow the funding stream intended to pay for their attendance; if the conference grant was reimbursing all or part of the participation costs for all attendees, it may be appropriate to also charge some or all of their cancellation fees. If participants were covering their own attendance costs (from sponsored or non-sponsored sources), then then the cancellation costs should follow the sponsor funding their participation or the participant’s employer.
For research questions, please email coronavirus_RO@mail.wvu.edu.