Questions and answers - Guidance on eligibility of COVID-19 potential costs
Last update: October 14, 2020
Question 1: Does the Guidance on eligibility of COVID-19 potential costs apply to all organizations implementing projects funded by Global Affairs Canada (GAC)?
The Guidance on eligibility of COVID-19 potential costs does not apply to all GAC programming; it applies solely to recipient organizations managing operational projects funded with a contribution agreement under the International Development Assistance Program. If an organization applies its internal policies or chooses to benefit from another COVID-19 relief program, costs listed in the guidance may not be eligible for reimbursement. For other GAC transfer payment programs, recipient organizations should contact their respective GAC project management teams.
Question 2: Does the guidance apply to grants?
The guidance applies solely in the context of contribution agreements under the International Development Assistance Program. Since grants are unconditional transfer payments, grant-funded organizations can apply their own internal policies.
Question 3: Does the guidance apply to contracts?
The guidance applies solely to contribution agreements under the International Development Assistance Program. Contractors should refer to Public Services and Procurement Canada and GAC contracting policies. Additional information can be found at Tender Management Application contacts and Buy and Sell.
Question 4: Does the guidance apply exclusively to Canadian individuals or organizations?
The guidance applies to all recipient organizations that have signed contribution agreements with GAC under the International Development Assistance Program and to their employees (and dependants), volunteers, interns and students. This includes Canadian and non-Canadian organizations and individuals.
Question 5: Does the guidance apply to subcontractors or consultants of the recipient organizations?
To implement their projects, recipient organizations may have entered into subcontracts with subcontractors (including consultants). The terms and conditions of these instruments are those of the recipient organizations (including their internal policies and rules). Consequently, from a legal standpoint, any extraordinary costs identified in the guidance and incurred by the recipient organization’s subcontractors or consultants would not be eligible for reimbursement by GAC funding. However, given the COVID-19 context, the program can determine eligibility on a case-by-case basis. Recipient organizations should contact their respective GAC project management team and take into account each subcontractor or consultant’s relationship with the project.
Question 6: Does the guidance apply to local partners of the recipient organizations?
To implement their projects, recipient organizations may have entered into sub-agreements with local partners. In such cases, provisions under the guidance (such as local partner employees’ salaries and office costs) are applicable. Recipient organizations should discuss foreseen project costs with their respective GAC project management team while taking into account that more than one donor could be funding the local partner(s).
Question 7: Why is the Technical Assistance Handbook referenced in the guidance, and how is it applied in the COVID-19 context?
The Technical Assistance Handbook already serves as a benchmark for maximum eligible amounts for various categories of benefits offered by recipient organizations to individuals assigned to a project funded by GAC.
In the context of the COVID-19 crisis specifically, certain provisions have been extended on an exceptional basis to cover the repatriation and, where necessary, subsequent relocation costs of volunteers, interns and students. This approach was deemed the most practical given that the vast majority of recipient organizations are already familiar with the Technical Assistance Handbook, which enables establishing maximum allowable benefits while taking into account the cost of living in the various countries in which Canada engages in international development. It is important to note that under no circumstances should benefits described in Chapter 4: Travel - Relocation and Chapter 11: Non Medical Emergency Evacuation be applied concurrently.
Question 8: Are quarantine and self-isolation costs eligible? If so, what type of expense is included and to whom do these apply?
Reasonable costs related to quarantine or mandatory self-isolation are eligible for project staff and their dependants (such as recipient organization’s headquarters and long-term assignment employees, as well as local staff), volunteers, interns and students who are unable to quarantine in their home city. The means of compensation for such costs are explained in chapter 11 of the Technical Assistance Handbook (for example, accommodation, meals and incidentals). If repatriated individuals can complete their quarantine or mandatory self-isolation in their own home, these costs will not be eligible.
Question 9: Does the guidance set a time limit for eligibility of expenditures related to the repatriation of project staff and their dependants, volunteers, interns and students?
The guidance does not set a time limit for the eligibility of costs related to the repatriation of any individual. However, recipient organizations should consider their duty of care responsibilities, Canadian and local governments’ measures (such as border closures) and public announcements to inform their decisions.
Question 10: Are safety kits and personal protective equipment eligible costs?
Reasonable costs related to basic safety kits used for the purpose of repatriation are eligible and will be reimbursed based on supporting receipts. In such circumstances, these would normally consist of masks and gloves.
Personal protective equipment provided for the purposes of project delivery (e.g. to project staff working in a public-facing role, volunteers, beneficiaries, participants directly involved in project activities and training sessions, etc.) can be considered eligible project expenses. The recipient organization must obtain prior written approval from the GAC project management team, and documentation for justification and rationale must be kept on the project file.
New Question 11: What does “incremental costs” mean?
An incremental cost is any new cost, or an increase to an existing cost, arising from the current circumstances due to the COVID-19 pandemic. For example, if an organization has an existing subscription to a teleconference service, this would be considered an indirect cost (overhead) and would not be an eligible project expense. However, if the organization needs to upgrade their subscription to allow for a greater number of employees to use the teleconference service, the additional cost to upgrade the subscription would be considered an incremental cost and could be an eligible project expense. In order for any incremental costs to be considered an eligible project expense, the recipient organization must obtain prior written approval from the GAC project management team and must provide supporting documentation (justification and rationale) to be kept on the project file.
Question 12: Once repatriated, if volunteers are able to resume their contribution to the project, will the deemed daily value already established for the purpose of the recipient organization’s cost share continue to count as their in-kind contribution?
If volunteers are able to continue working on project activities after being repatriated, organizations are encouraged to submit a request to GAC to modify the volunteers’ status to e-volunteer. Requests will be assessed on a case-by-case basis depending on the extent to which the proposed arrangements will contribute to achieving concrete project results while ensuring that the organization’s in-kind contribution remains accurate.
In cases where the recipient organization’s in-kind cost-share capacity is limited due to COVID-19, the GAC project management team has the flexibility to revise the in-kind cost-share obligations. While these decisions do not trigger an amendment to the contribution agreement, the supporting rationale should be well documented by all parties using email exchanges.
Question 13: Once repatriated, if volunteers are able to resume their contributions to the project, will an overhead allowance of 12% of a deemed $200 per day value continue to be paid to the recipient organization?
If repatriated volunteers are able to work remotely, the organization cannot claim the time worked in Canada and receive the overhead compensation, given that no costs would be incurred in the country of assignment.
Question 14: By when must recipient organizations communicate with their respective GAC project management team about their reassessment of the project’s feasibility?
While there is no deadline to do so, discussions on the best course of action should happen as early as possible. In order to relieve the short-term financial pressure on recipient organizations, GAC has provided a measure by which the equivalent of up to 30 working days per position already assigned to a project could be reimbursed when work toward direct project activities cannot be performed.
This 30-day salary measure starts on the day after project activities are paused due to COVID-19-related restrictions and is applicable to the recipient organization’s employees (headquarters and long-term assignment employees, and local staff) working on GAC-funded projects. Affected employees’ salaries should continue to be paid based on the pre-negotiated levels of effort (for example, on a full-time or part-time basis). Recipient organizations should use the 30-day period to determine whether project activities can be maintained.
Such measures should not be applied beyond the duration of the COVID-19 crisis or beyond the day on which a final decision on the respective positions’ roles in the redefined project is made, whichever comes first, and up to a maximum of 30 days. If the organization’s employee is not able to contribute to the project remotely beyond the 30th day, his or her salary cannot be claimed by the recipient organization as an expense eligible for reimbursement by GAC. Should this be the case, the employee is encouraged to benefit from other announced Government of Canada subsidy measures.
If the recipient organization’s employees can resume working on project activities remotely after repatriation, the 30-day limit will not apply, and they will continue to receive their salary as usual. In this case, the salary paid to the individual must be representative of the level of effort toward the project.
Question 15: What happens if project activities are not resumed within the 30-working-day period and the Canadian partner must lay off staff in a country that legally requires a certain length of time between the issuance of a layoff notice and the end of employment?
Reasonable costs incurred to cover the legally required length of time to lay off local employees are eligible. However, these costs should not be confused with severance pay obligations, which are only attributable to GAC according to the individual’s position being assigned to projects funded by GAC. Severance pay is an existing responsibility of the organization; it is expected that the organization already has a system in place to make such allocations. Therefore, it is not an additional measure.
Question 16: Is the flexibility offered through the guidance only applicable to COVID-19-crisis-related costs?
The additional flexibility offered through the guidance is only applicable to COVID-19-crisis-related costs and amendments for contribution agreements. The guidance cannot be used if no cause-effect relationship between the COVID-19 crisis and the project activities can be demonstrated.
It is the GAC project management team’s responsibility to ensure proper documentation of any flexibility measures provided to the recipient organizations under the guidance.
Question 17: What flexibility can be offered without amending the contribution agreement?
Recipient organizations must contact the GAC project management team responsible for their project. For the COVID-19 crisis only, the following amendments, if approved, can be documented using email exchanges between the GAC project management team identified in the contribution agreement and the recipient organization:
- Time extensions with no impact on the current total approved project budget
- Changes to activities that do not modify the intermediate and ultimate outcomes
- Reallocation of funds between budget line items and categories, including increases in the remuneration category, which do not result in an increase to the value of the agreement
- Revision of in-kind cost-share obligations
Both parties should document their analyses and decisions on file for eventual audit purposes, as these changes constitute amendments to the signed contribution agreements.
The following changes require a written amendment to the contribution agreement issued by GAC and signed by both parties:
- Changes to intermediate and ultimate outcomes
- Changes to the overall contribution agreement project value
- Any other change requiring an amendment that is not otherwise granted exceptions above
Question 18: Can a recipient organization that currently has an operational contribution agreement with GAC modify certain project activities to address some of the immediate COVID-19 issues in the country of their project?
If recipient organizations currently working on GAC-funded projects wish to channel certain project efforts toward addressing COVID-19-crisis-related activities in the project country, they can do so as long as the project’s intermediate and ultimate outcomes, and the value of the contribution agreement, do not change. This is subject to the prior approval of the GAC project management team and appropriate documentation of such change to the contribution agreement (for example, submitting the revised budget with proposed reallocation of funds; submitting proposed changes to activities, procurement and geographic targets). Any change to the ultimate and intermediate outcomes should be made through a written amendment reflecting the approved changes issued by GAC and signed by both parties.
Question 19: What is a minimum amount of activity required to justify continued payment of salaries?
Salaries (beyond the “up to 30 working days” measure explained in Question 13) should not be claimed by the recipient organizations (whether it is the organization’s headquarters or long-term assignment employees or local staff) unless the employees in these positions are able to continue their functions either on-site or remotely.
If only a portion of the work can continue, the project activities should be documented, and the respective salaries should be claimed in accordance with the positions’ revised levels of effort. In this case, time sheets are not mandatory to substantiate the revised time allocation toward GAC project activities. Email exchanges with the GAC project management team are preferred; where this is not feasible, a proper documentation of the rationale should be kept on file by the recipient organization and provided to GAC upon request.
GAC officials are currently coordinating with central agencies on additional Government of Canada measures to minimize the financial impacts of the COVID-19 crisis beyond international development assistance project funding. Recipient organizations and their employees are encouraged to regularly refer to these questions and answers for updates to information.
Revised Question 20 : Can recipient organizations claim costs as per the guidance as well as through other government-announced measures, if applicable?
Recipient organizations must remain transparent in how they are mitigating the financial impacts of the COVID-19 crisis on the delivery of GAC-funded projects. Certain costs, such as salaries of the organization’s Headquarters and long-term assignment employees or local staff, may be eligible for financial relief through multiple sources. In such cases, organizations must ensure that reimbursement from one or more sources of funds (federal, provincial or municipal governments, or other third parties) must not overlap and must not be greater than the actual costs. Furthermore, it is the organization’s responsibility to ensure that any GAC contribution to the project is compatible with all other subsidies received for the same expenses, and to inform GAC as soon as possible of any overlap or incompatibility between sources of funding. It is also the organization’s responsibility to report to GAC all funds received as the result of emergency measures or from governmental programs related to COVID-19. GAC reserves the right to verify the amounts received and the costs claimed related to these measures and programs.
For example, if an employee is working on a GAC-funded project with a 50% level of effort and this portion is being charged to the GAC project, the organization can apply for other governmental programs to subsidize the remaining 50% of the employee’s salary not covered by GAC funds. If, because of a slowdown in activities, the organization cannot justify a 50% level of effort but can only justify 25% to be charged to the GAC-funded project, then the organization could consider seeking support from other governmental programs for the remaining 25% of GAC’s portion. Organizations must ensure that no positions are subsidized through government programs and other donors at a rate higher than 100% for a given position. It is also important to note that this applies to any project costs that are subsidized by multiple sources of funds.
New Question 21: If a recipient organization is unable to ensure project continuity on a temporary basis (that is, unable to continue achieving project results because of the COVID-19 pandemic), what should it do?
Recipient organizations are responsible for managing, monitoring and implementing the GAC-funded projects and ensuring that results are achieved as indicated in the contribution agreements. Furthermore, recipient organizations are responsible for ensuring that any funds received from GAC through the International Development Assistance (IDA) program are used solely for IDA programming.
To that effect, recipient organizations must advise GAC of any issues that impact their ability to implement the project—with any alternative approaches, where applicable. If a country in which a GAC-funded project is being implemented has been placed under a temporary lockdown due to the COVID-19 pandemic, it is possible that project activities will be reduced and project results will not be achieved. In any situation where project results cannot be achieved because of the COVID-19 pandemic, recipient organizations must discuss their specific case with their GAC project management team to determine the best course of action. GAC reserves the right to suspend the project (partially or fully) to ensure the optimal use of programming funds. This will ensure that project funding is not disbursed in a situation where project results cannot be achieved. Once the project activities can reasonably be resumed and project results can be achieved, the GAC project management team and the recipient organization can re-evaluate the project status to resume disbursement of project funds. In such a case, resuming the disbursement of project funds will be done after an assessment of the scope of the project and could be subject to an amendment.
Question 22: How will the GAC project management team and recipient organization be able to establish or revise ongoing financial needs for project implementation?
Given the nature of transfer payments, the governing Treasury Board of Canada Secretariat Directive on Transfer Payments requires that advance payments of a contribution, where they are essential to the achievement of objectives, be specifically provided for in the funding agreement and be based on the recipient’s cash flow requirements.
While GAC intends to offer flexibility, these requirements must continue to be met. Discussions between the GAC project management team and recipient organization, in light of information available, are the best means to ensure compliance.
The Directive on Transfer Payments also requires timely accounting from recipients to ensure that advance payments are being spent for authorized purposes and that unspent balances in the hands of recipients are reasonable and consistent with the recipient’s cash flow requirements.
Consequently, given exceptional circumstances, GAC has adapted its expectations in terms of “timely accounting from recipients.” More precisely, while the same financial reporting cycle documented in the contribution agreement continues to apply (whether monthly, quarterly, semi-annual or annual advances), a third advance could exceptionally be issued even if the 2 previous advance periods remain unjustified and unaccounted for due to the COVID-19 crisis.
New Question 23: Can a recipient organization submit a partial PIP?
Organizations may choose to submit a partial PIP for the first year of a project where the completion of the full PIP through virtual meetings is not possible. This is subject to the organization obtaining prior written approval from the GAC project management team.
A partial PIP could be submitted to outline the project activities that will take place while travel restrictions are still in place.
New Question 24: What happens if an organization is granted an extension on their project implementation plan (PIP) submission deadline but is unable to deliver the PIP by the new deadline?
In order for an organization to receive an extension for the PIP submission deadline (i.e. an additional 120 days as per the guidance), they must provide the GAC project management team with a concrete plan on how they will be able to complete the PIP remotely through virtual meetings within the additional time allotted. If the organization cannot adequately demonstrate how the PIP will be completed, or submit the PIP within the extended period, the GAC project management team may decide to suspend the project.
Question 25: Does the COVID-19 temporary holdback approach apply to all Global Affairs Canada (GAC) programming?
The temporary approach applies to the International Development Assistance Program. All other transfer payment programs may consider the temporary approach on holdback, subject to their program’s operational process and terms and conditions.
Question 26: Will the COVID-19 temporary holdback approach apply automatically to all eligible projects?
The flexibilities provided by the temporary approach will not apply automatically to eligible projects. Recipient organizations with eligible projects should submit a request to their respective GAC project management teams with the information required under the temporary approach.
Question 27: If the COVID-19 pandemic ends prior to the termination of a project (either in 2020 to 2021 or 2021 to 2022), will any holdback decisions taken under the COVID-19 temporary holdback approach remain in effect or will the original holdback requirements (i.e. 5% of GAC’s full contribution, no maximum) be re-enforced?
The holdback decisions taken under the COVID-19 temporary holdback approach will remain in effect throughout the remainder of the project’s life regardless of the status of the COVID-19 pandemic.
Question 28: Once a holdback decision is made under the COVID-19 temporary holdback approach, can it be altered (e.g. the program has decided to apply a tiered holdback approach to a project ending in 2020 to 2021, but would later like to revise the decision to release 100% of the holdback)?
The program must assess all factors as outlined in the application of the COVID-19 temporary holdback approach and unforeseen risks, and make a decision based on this assessment. Due to the constantly evolving nature of the COVID-19 pandemic, it is possible that these factors could change after a holdback decision has been made. Therefore, the program can reassess the project’s standing and can revise a holdback decision while respecting the requirements of the COVID-19 temporary holdback approach.
Question 29: If a project ending in 2020 to 2021 is allowed to have its holdback released as per the COVID-19 temporary holdback approach, but subsequently receives a no-cost time extension where the new project end date is in 2021 to 2022, will it still be eligible to receive the full holdback released as per the decision taken under the temporary measure?
Each project is assessed on a case-by-case basis, and the program must take into account any factors that change throughout the life of the project, including unforeseen risks. Therefore, in any exceptional situations that might affect the holdback decisions taken under the temporary approach, recipient organizations should contact their respective GAC project management teams for guidance.
New Question 30: If an organization is unable to meet its cash cost-share obligation due to a decline in fundraising revenues as a direct result of the COVID-19 pandemic, can the cash cost-share amount be reduced or waived?
GAC recognizes the impact that COVID-19 may have on fundraising activities during 2020. Since fundraising is an ongoing activity and may not have a negative impact on the ability to meet cash cost-share obligations in future years of the project, the recipient organization should explore options with its respective GAC project management team. Such options might include:
- delaying project cash contribution and realigning the corresponding activities, where possible
- considering another type of contribution, such as in-kind contribution
As a last resort, the organization can alert the GAC project management team of the delay in the anticipated cash contribution schedule and state that planned fundraising cannot be achieved. The organization can then submit a formal request to the GAC project management team for a reduction or deferral of the cash cost-share obligation. The request should include an explanation of the organization’s fundraising capacities and fundraising plans in the pandemic context.
GAC will assess these requests on a case-by-case basis and consider a partial waiver of cost-share obligations for operational projects that are in their final year only. For projects with multiple years remaining in the life cycle, GAC may consider a deferral of the current year’s cash cost-share contribution to a future year. Any reduction or deferral of the cash cost-share contribution will be based proportionally on the total value of the cost-share over the full life of the project (for example, a reduction or deferral of 1 year’s cash contribution in a 5-year project will be the equivalent of 1/5 of the total cash cost-share contribution).
Should a recipient organization opt for a transfer between cash and in-kind (or vice versa), this transaction must not create any additional financial obligation for GAC or negatively impact expected project results. If the cash contribution is deferred to future years, the deferred portion cannot be reduced later. Once a deferral or reduction of cash cost-share has been approved, the recipient organization and the respective GAC project management team must maintain proper tracking and documentation for audit purposes.
New Question 31: If a recipient organization deferred its cash cost-share obligations in previous years and requests a reduction in cost-share in the final year of the project, can the total outstanding amount of the cash cost-share be waived?
If the cash cost-share contribution has been deferred in previous years (for 1 or more years), GAC cannot waive the accumulated cost-share obligation. The amount of cash cost-share waived must be proportionate over the lifetime of the project and not an accumulated cost-share over the years. For example, if cash cost-share has been deferred for years 3 and 4 in a 5-year project, then 3/5 of the cash cost-share requirement will be outstanding in year 5 (the final year) of the project. If the recipient organization requests a reduction of cash cost-share in the final year, a maximum of 1/5 of the total value of the cash cost-share contribution in the project can be waived. The organization will be responsible for providing the remaining 2/5 outstanding cash cost-share contribution, which had been deferred from previous years.
New Question 32: If a recipient organization decides to replace its cash cost-share obligation by an in-kind contribution (for example, volunteering services), will the 12% overhead apply on the deemed daily value of these volunteers?
Since the transfer between cash and in-kind contribution is an exceptional, COVID-19 measure, any change to cost-share obligations (including the waiver of the project’s last year of the cost-share obligation) must not result in an increase of GAC’s contribution.
New Question 33: Can the in-kind contribution from a recipient organization be broadened to include other types of in-kind contribution?
The GAC project management team may consider other in-kind contributions as long as they are in accordance with the direct eligible project expenditures and eligibility requirements of the in-kind contributions consistent with the Policy on Cost-Sharing for Grant and Non-Repayable Contribution Agreements.
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