Venable – On April 9, 2020, OMB issued its third memorandum in a series responding to COVID-19 from a federal financial assistance perspective. While the first two memoranda provided flexibilities for grant recipients, the latest memorandum directs all federal departments and agencies “to marshal all legally available federal resources to combat the crisis.” Specifically, memorandum M-20-20, “Repurposing Existing Federal Financial Assistance Programs and Awards to Support the Emergency Response to the Novel Coronavirus (COVID-19),” is a class exception, pursuant to 2 C.F.R. § 200.102(a), permitting federal awarding agencies to “repurpose” their awards to support the COVID-19 response.
