OMB told federal agencies to “marshal all legally available federal resources to combat” the Coronavirus pandemic, issuing a class exception allowing them to “repurpose their federal assistance awards (in whole or part) to support the COVID-19 response, as consistent with applicable laws.”
Said memo M-20-20, “As an example of this flexibility, agencies may allow recipients to donate medical equipment (including, but not limited to, personal protective equipment, medical devices, medicines, and other medical supplies) purchased with federal assistance funds to hospitals, medical centers, and other local entities serving the public for COVID-19 response. This class exception also extends to the donation of other resources (such as labor, supplies, and contract services) funded under federal financial assistance to support COVID-19 emergency response activities.”
Agencies must pass any such awards through their legal counsel’s offices first, maintain records, and “advise recipients that they should not assume additional funds will be available should the donations or repurposing of funds result in any type of shortage,” it says.
Separately, in memo M-20-21, OMB issued guidance on spending under the three relief laws enacted so far, saying that while “time is of the essence,” agencies are to “leverage and continue to employ existing financial transparency and accountability mechanisms wherever possible.”
Key considerations, it says, are that “federal managers and recipients at all levels should use data and evidence to achieve program objectives”; “agencies should rapidly issue awards and fund programs to meet crucial needs”; and “agencies must report information on awards to provide the public with information in a clear, accurate, and timely manner.”