Type: Law Bulletins
Date: 04/10/2020

OMB Gives Agencies Authority to Repurpose Federal Financial Assistance

On April 9, 2020, the Office of Management and Budget (OMB) issued Memo M-20-20 (Memo M-20-20), new guidance instructing federal executive agencies to marshal all of their legally available resources toward combatting COVID-19.

Drawing on authority in 2 CFR 200.102(a): Exceptions, OMB issued a class exception, permitting agencies to repurpose their federal assistance awards. Memo M-20-20 provides two sets of examples: 1) medical equipment, including personal protective equipment, medical devices, medicines and supplies, previously purchased with federal grant funds may now be donated and 2) the donation of labor, supplies and contract services for emergency response.

Grant awardees should contact their grant officers. The memo cautioned that any repurposed funding still be required to meet its legal compliance obligations with regard to purpose, amount and time, as well as any restrictions in programmatic statutes, appropriations and fiscal laws. Grant awardees should not assume additional funds will be available to make up any shortage down the road.

Please visit our COVID-19 Toolkit for all of Taft’s updates on the coronavirus.

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