Most of the U.S. Federal Government Grants and Contracts received by WHOI make allowance for the possibility of a No-Cost Extension (NCE) – a period of time beyond the original expiration date that can be used to complete the proposed work but without any additional funds. In all cases the request should be justified and the fact of “left-over” money is not sufficient justification. Likewise, as the award is made to WHOI, the request for an extension, or any other formal award modification, must be co-signed by the Grants and Contracts Office (GCS).
Each agency has slightly different statements regarding the process for NCE:
DEPARTMENT OF ENERGY
Recipients of research awards may extend the expiration date of the final budget period of the project if additional time beyond the established expiration date is needed to assure adequate completion of the original scope of work within the funds already made available. A single extension, which shall not exceed twelve (12) months, may be made for this purpose, and must be made prior to the originally established expiration date. The recipient must notify the cognizant DOE Contracting Officer in the awarding office in writing within ten (10) days of making the extension.
This is an “expanded authority” regulation. Rather than asking for the NCE, WHOI only has to notify them that we are taking our option to extend for up to 12 months. The PI and/or Department Administration must send the request with Justification for our file to the DOE Grant Administrator (Steve Murphy) at least 12 working days before the expiration of the project.
NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
NASA allows recipients to initiate a one‑time extension of the expiration date of the award of up to 12 months unless one or more of the following conditions apply. For one‑time extensions, the recipient must notify NASA in writing with the supporting reasons and revised expiration date at least 10 days before the expiration date specified in the award. This one‑time extension may not be exercised merely for the purpose of using unobligated balances.
(i) The terms and conditions of award prohibit the extension.
(ii) The extension requires additional Federal funds.
(iii) The extension involves any change in the approved objectives or scope of the project.
The PI and/or Department Administration must send the request with Justification for our file to the NASA Grant Administrator (Bonnie Griffin) at least 12 working days before the expiration of the project. Email will be sent to the appropriate grant processing office and to the Program Manager by GCS.
Should additional NCE be needed, PI and/or Department Administration must prepare a formal request, with a place for GCS to co-sign the request, addressed to the NASA Grant Officer, with a copy to the Program Manager (Technical Officer) and to the Administrative Contract Officer (ACO - Eric Garfield). These letters should be sent to GCS, who will complete the process of signing and mailing.
NATIONAL INSTITUTES OF HEALTH
At NIH, generally all grantees may extend the final budget period of the previously approved project period one time for a period of up to 12 months beyond the original expiration date shown in the Notice of Award, if, as referenced in the NIH Grants Policy Statement:
The fact that funds remain at the expiration of the grant is not, in itself, sufficient justification for an extension without additional funds.
To obtain the no-cost extension use the No-Cost Extension feature via eRA Commons, an electronic means for a grantee organization to electronically submit a notification that they have exercised their one-time authority to extend without funds the final budget period of a project period of a grant. Upon receipt of the notification, the budget and project period end dates are automatically updated to reflect the extension of the respective grant record. No separate action is needed by agency staff for this change to take effect. An email notification is automatically sent to agency staff when the grantee submits the extension notification. To initiate an entry to the electronic system forward the request and justification to GCS who must enter into eRA Commons.
NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION
All Post Award Action requests must be completed in Grants Online. General Guidance:
NOAA requires that ALL Award Action Requests be approved by a Recipient Authorized Representative (GCS). Grants Online enforces this business rule by routing all requests through the Recipient Authorized Representative for submission to NOAA.
An Award End Date may ONLY be extended through:
A No-Cost Extension – Invocation of Expanded Authority must be submitted to NOAA 10 or more days prior to the Award End Date. Grants Online automatically enforces this business rule.
A No-Cost Extension – Without Invocation of Expanded Authority is required to be submitted to NOAA 30 or more days prior to the Award End Date. Failure to meet this requirement is sufficient grounds for rejection of the request by NOAA.
Recipients having Expanded Authorities must exercise their No-Cost Extension – Invocation of Expanded Authority before they request a No-Cost Extension – Without Invocation of Expanded Authority. Enforcement of this rule is at the discretion of the Grants Specialist.
The PI and/or Department Administration must prepare the request with appropriate justification in Grants Online and “submit”. This will generate an email to GCS that we have to approve and submit a request to NOAA. Adherence to the deadlines stated above is required. Additional time should be given in case there are any problems encountered with Grants Online.For more information see the "Related File" - NOAA NO-COST EXTENSIONS
NATIONAL SCIENCE FOUNDATION
(i) Grantee-Approved Extension.
Grantees may authorize a one-time extension of the expiration date of the grant of up to 12 months if additional time beyond the established expiration date is required to assure adequate completion of the original scope of work within the funds already made available. This one-time extension may not be exercised merely for the purpose of using the unliquidated balances. Grantees are not authorized to extend an award that contains a zero balance. The grantee shall notify NSF, providing supporting reasons for the extension and the revised expiration date, at least ten days prior to the expiration date specified in the grant to ensure accuracy of NSF’s grant data. All grantee-approved extension notifications must be submitted via the FastLane system. For grantee-approved extensions, no amendment will be issued.
(ii) NSF-Approved Extension
(a) If additional time beyond the extension provided by the grantee is required and exceptional circumstances warrant, a formal request must be submitted to NSF via FastLane. The request must be submitted to NSF at least 45 days prior to the expiration date of the grant. The request must explain the need for the extension and include an estimate of the unobligated funds remaining and a plan for their use. As indicated above, that unobligated funds may remain at the expiration of the grant is not in itself sufficient justification for extensions must be submitted via the FastLane system. NSF program officers are authorized to approve the first no cost extension request on current active awards.
(b) The first no-cost extension request will be subject to the approval of the cognizant Program Officer. The sponsored projects office and PI will be electronically notified of the disposition of this request by the cognizant NSF Program Officer. The second no-cost extension will continue to be subject to the approval of an NSF Grants and Agreements Officer, and, if approved, will be in the form of an amendment to the grant specifying a new expiration date. Grantees are cautioned not to make new commitments or incur new expenditures after the expiration date until the official award modification has been received.
(c) Grantees are not authorized to extend an award that contains a zero balance.
The PI and/or Department Administration must prepare the request with appropriate justification in FastLane and “submit”. This will generate an email to GCS that we have to approve and submit a request to NSF.
OFFICE OF NAVAL RESEARCH
Extension of the expiration period of a Grant – The AGO at the Administrative Office in Block 23a of the Award/Modification document has authority to approve no funds extension requests meeting all of the following parameters:
In other cases, where a request is outside one or more of the parameters, a no funds extension can only be approved with the concurrence of the ONR Program Officer/Technical Representative in Block 21 of the Award/Modification document. For any no funds extension to be effective, a written grant modification must be issued and signed by the AGO at the Administrative Office in Block 23a or the Awarding Office in Block 22 of the Award/Modification document.
Recipients of research awards may request an extension to the expiration date of the grant period of the project if additional time beyond the established expiration date is needed to assure adequate completion of the original scope of work within the funds already made available. The fact that funds remain at the expiration date of the award is not in itself sufficient justification for an extension without additional funds. The PI and/or Department Administration must prepare the request with appropriate justification and email to the GCS ONR Grants Administrator (Bonnie Griffin). This should be done at least 90 days before the expiration date. The email request should provide the information below and a JUSTIFICATION for the request. If prior approval has already been received from the Program Manger, attach that email approval. Be sure to include the desired new Expiration Date. GCS will send the official request to our Administrative Contracting Office (ACO) in Boston, Mr. Eric Garfield, via email. If Program Manager approval is not evident, Eric will contact him/her directly.
Remember, that Program Manager approval is not sufficient and Eric Garfield will not give any approval until he has the official request from GCS. A late request (especially after the expiration date) is very difficult to get approved. You are cautioned not to make new commitments or incur new expenditures after the expiration date until the official award modification has been received.
OTHER AGENCIES AND FOUNDATIONS
As other agencies and foundations have different requirements for obtaining no-cost extension, see the award document or call GRANT AND CONTRACT SERVICES for guidance.