Important Subrecipient Information and Guidance
As we continue to monitor the Coronavirus (COVID-19) situation and the uncertainty related to when everyone's normal business operations may resume, we will update this page with important information and guidance for our subrecipients.
For the latest information on COVID-19, please visit the Pennsylvania Department of Health: Pennsylvania Coronavirus Updates. Information can also be found on their Facebook page and Twitter account. In addition, a resource guide for how Pennsylvania is responding to COVID-19 is available at https://www.pa.gov/guides/responding-to-covid-19/
New Process for PCCD Grant Application and Project Modification Request Signatures – Effective Immediately Until Further Notice
Please attach a copy of the signed signature page (page 2 of your application) to any section of your application that accepts attachments within Egrants. If that is not possible or if you are experiencing difficulty, you may also email a copy of the signature page (page 2 of your application) to the fiscal contact identified on the Main Summary page of your application in Egrants or you may email the signature page to firstname.lastname@example.org. You are not required to mail the original signature page as described in the funding announcement you are responding to. Please review page 14 of PCCD's Applicant's Manual for direction on who must sign this page for your organization.
Project Modification Requests
Most project modification requests (PMRs) will be processed in Egrants without requiring signatures. For PMRs that can be processed without signatures, simply submit your PMR in Egrants and all contacts identified on the Main Summary page in Egrants will be notified by an automated alert from Egrants that their PMR was approved or requires correction or additional information. You are not required to mail anything to PCCD for these types of PMR's.
Signatures are required on page two of the PMR in the following situations:
1. You want to modify the project period
2. You want to modify the award amount
3. You want to make a significant change to the project's scope or objective (please discuss this with your PCCD program contact prior to submitting a PMR).
Please email a signed copy of page 2 of the PMR to the fiscal contact identified on the Main Summary page of your PMR in Egrants or you may email the signature page to email@example.com. You do not need to mail anything to PCCD. Please review page 14 of PCCD's Applicant's Manual for direction on who must sign this page for your organization.
No-Cost Grant Extension Requests
Recognizing that project implementation has likely been impacted by this situation, PCCD will be receptive to project period extension requests where possible. In some instances, our ability to grant an extension request will be dependent on the availability of the requisite funding. If your grant is scheduled to end in the next six (6) months and you anticipate the need for a no-cost extension, you may email RA-PCCDGrantsMgmt@pa.gov for guidance if you are unsure if your grant is able to be extended
Quarterly Program and Financial Reporting
PCCD recognizes that some may not be able to submit their quarterly reports by the April 20th deadline. The PCCD Egrants system will continue to send reminder notifications related to reports that have not been submitted, however, there will be no adverse action taken by PCCD related to late reports. We would encourage you to make the submission timely so that reimbursement payments are continued.
PCCD Funding Announcements
There are several funding announcements currently open and most of the competitive announcement submission deadlines have already been extended. We will continue to monitor these closing dates and may extend further dependent upon the current situation and organizations' abilities to appropriately make application. Please check PCCD's website at https://www.pccdegrants.pa.gov/Egrants/Public/OpenAnnouncements.aspx to view current deadlines for PCCD's open competitive funding announcements. You can also view current open funding announcements in PCCD's Egrants system.
PCCD staff will continue to process financial reimbursement requests.
Interruptions in performance of work under the grant
PCCD recognizes there could be a reduction in service provision resulting from COVID-19. Subrecipients should use their existing policies (e.g. telework, leave, office closings, etc.) to address service provision and employee absences. As always, PCCD grant funding can support payments for leave for currently funded complement. All PCCD grantees should have a written leave policy in place. For federal or state funded projects, we will be applying the federal guidelines for cost principles related to leave which are copied below and can be found at 2 CFR 200.431(b). We encourage you to review the entire section (2 CFR 200.431) related to fringe benefits.
2 CFR 200.431(b):
(b) Leave. The cost of fringe benefits in the form of regular compensation paid to employees during periods of authorized absences from the job, such as for annual leave, family-related leave, sick leave, holidays, court leave, military leave, administrative leave, and other similar benefits, are allowable if all of the following criteria are met:
They are provided under established written leave policies;
The costs are equitably allocated to all related activities, including Federal awards; and,
The accounting basis (cash or accrual) selected for costing each type of leave is consistently followed by the non-Federal entity or specified grouping of employees.
When a non-Federal entity uses the cash basis of accounting, the cost of leave is recognized in the period that the leave is taken and paid for. Payments for unused leave when an employee retires or terminates employment are allowable in the year of payment.
The accrual basis may be only used for those types of leave for which a liability as defined by GAAP exists when the leave is earned. When a non-Federal entity uses the accrual basis of accounting, allowable leave costs are the lesser of the amount accrued or funded.
Paycheck Protection Program (PPP)
In the event that a subrecipient receives a PPP loan, the subrecipient must ensure that PPP funds and PCCD grant funds are not paying for the same item. PCCD will actively monitor for this issue and if duplication as described below is found to have occurred, PCCD will pursue corrective action including a required reimbursement of the duplicated payment.
The following guidance regarding duplication and supplanting related to the federal Paycheck Protection Program (PPP) is the current federal guidance. PCCD will apply this guidance to all federal and state PCCD grant programs.
Duplication occurs when the subrecipient uses VOCA Assistance funds to pay for specific costs already covered by other sources. For example:
- If the subrecipient pays a staff position from the PPP loan then draws down grant funds to cover the same staff position, but never pays the loan back because it was forgiven, the subrecipient may have duplicated costs (or otherwise made an improper payment, see 2 C.F.R. 200.53), unless the forgiven loan funds are allocated to a different cost item. For example:
- The PPP loan paid salary for employee 1, but then reallocated to pay salary for employee 2, and then used the grant funds to pay for employee 1.
- If the subrecipient pays back the loan, it would not be duplication.
when a subrecipient intentionally replaces its other state or local victim service funding
sources with grant funding. For example:
- If a subrecipient uses grant funds to replace a PPP loan, then repays that loan instead of keeping the loan funds under the forgiveness provisions, it would not be supplanting.
If a subrecipient uses grant funds to replace a PPP loan, then uses those loan funds for another expense (whether the loan is forgiven or not), it typically would not be supplanting because PPP funding is not designated for specific grant program purpose.
Cancellations as a result of COVID-19
Conferences, events, and other gatherings: For PCCD-sponsored conferences, meetings, trainings, and other gatherings that are scheduled in the near term, PCCD grant recipients should work to set up such events as virtual events or postpone events until a later date. If converting to a virtual event or postponement is not possible, grantees should cancel near-term events.
Please contact your PCCD program manager listed in the Main Summary section of your Egrants application should you be required to cancel an event or incur costs for postponement or cancellation of event.
Airline ticket cancellations: Grantees should try to have the airline reimburse the canceled ticket(s) in cash. However, if the airline will only refund the cancellation as a credit.
- The grantee should apply the credit to a future trip for the same PCCD grant or project.
- If you have other PCCD funded project which you believe you may be able to apply the credit to, please contact your PCCD program manager listed in the Main Summary section of your Egrants application.
- If you are unable to use the credit as described above, then you should process the trip as a cancellation, which PCCD approves to be charged to the grant due to this mitigating circumstance.
Closure of non-life sustaining businesses: As a result of recent health and safety concerns related to the spread of novel Coronavirus (COVID-19), we want to ensure that our grantees are aware of Governors Wolf's order to close the physical locations of all non-life-sustaining businesses. Governor Wolf's Order, the Secretary of Health's Order and additional information such as a list of life-sustaining businesses, enforcement actions, resources and industry-specific guidance can be found at https://www.pa.gov/guides/responding-to-covid-19/#ForBusinesses.
If you have questions regarding whether your business(es) need to close, you can direct those questions to firstname.lastname@example.org, and any questions regarding how to apply for a waiver or further information on that process should be directed to RAemail@example.com.