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No Cost Extensions

All requests to be sent to GCS for Authorized Signature & Submission

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A no-cost extension extends the project period beyond the original project end date. As the phrase “no cost” suggests, there is no additional funding. A no-cost extension may be requested by the PI when all three of the following conditions are met:

  • The end of the project period is approaching, AND
  • There is a programmatic need to continue the research, AND
  • There are sufficient funds remaining to cover the extended effort

Most of the U.S. Federal Government Grants and Contracts received by WHOI make allowance for the possibility of a No-Cost Extension (NCE).  In all cases the request should be justified and the fact of “left-over” money is not sufficient justification.  It is good practice to request the extension in enough time to manage an orderly accomplishment of project work, and to have a contingency plan in case the sponsor does not approve the extension.

Written requests for no-cost extensions should be prepared by the PI and then endorsed and submitted by GCS.  Department Administrators and Principal Investigators should not submit No Cost Extensions on their own.  GCS Grant Administrator assignments are located at: http://www.whoi.edu/page.do?pid=21987 if you are not certain to whom your request should be directed.

Some sponsors have developed electronic systems to handle no-cost extension requests and approvals. 

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 at least 12 working days before the expiration of the project.

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

NASA grant recipients may make a one-time no cost extension, not to exceed 12 months, prior to the established expiration date. Written notification of such an extension, with the supporting reasons and the progress report, must be received by the NASA Grant Officer at least ten (10) days but no sooner than thirty (30) days prior to the last day of the period of performance. NCE requests sent via email are not accepted by NASA Program Managers and should be directed to the appropriate Grant Administrator who will submit the information on the NASA Shared Services Center (NSSC).   Failure to submit the necessary documentation and progress report may result in non-acceptance of the request or other enforcement actions as provided in 2 CFR 200.338. 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.

All NASA No Cost Extension requests require the following information:

  • Grant Number
  • Type of Extension – 1st No Cost Extension, 2nd No Cost Extension, 3rd No Cost Extension
  • New Proposed End Date
  • Justification (1,000 character limit)
  • Current Progress Report attached

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:

  • no additional funds are required to be obligated by the NIH awarding office
  • the project’s originally approved scope will not change, and
  • any one of the following applies:
    1. Additional time beyond the established expiration date is required to ensure adequate completion of the originally approved project
    2. Continuity of NIH grant support is required while a competing continuation application is under review
    3. The extension is necessary to permit an orderly phase-out of a project that will not receive continued support

The fact that funds remain at the expiration of the grant is not, in itself, sufficient justification for an extension without additional funds.

  • In extending the final budget period through this process, the grantee agrees to update all required certifications and assurances, including those pertaining to human subjects and animal welfare, in accordance with applicable regulations and policies.  All terms and conditions of the original award continue during the extension period.

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 funded amendment through an application (SF-424)

  •   A No-Cost Extension – Invocation of Expanded Authority

  •   A No-Cost Extension – Without Invocation of Expanded Authority

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.

NATIONAL SCIENCE FOUNDATION

(i)                 Grantee-Approved Extension.

Grantees may authorize a one-time extension of the end date of the grant of up to 12 months if additional time beyond the established end date is required to assure adequate completion of the original scope of work within the funds already made available. A single extension, which shall not exceed 12 months, may be made for this purpose and must be made prior to the originally established end date. As stipulated in 2 CFR § 200.308(d)(2), this one-time extension may not be exercised merely for the purpose of using any 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 period of performance, at least ten calendar days prior to the end date specified in the grant to ensure accuracy of NSF’s award data. All grantee-approved extension notifications must be signed and submitted by the AOR via use of NSF’s electronic systems. For grantee-approved extensions, no amendment will be issued. The revised end date can be viewed via NSF's electronic systems.

(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 signed and submitted by the AOR via use of NSF’s electronic systems. The request should be submitted to NSF at least 45 days prior to the end date of the grant. All late requests must include a strong justification as to why it was not submitted earlier. 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 end of the grant is not in itself sufficient justification for an extension. The plan must adhere to the previously approved objectives of the project. Such requests must be signed and submitted by the AOR via use of NSF’s electronic systems.

(b) The first no-cost extension request will be considered for approval by the cognizant NSF Program Officer. The grantee and the PI will be electronically notified of the disposition of this request by the cognizant NSF Program Officer (an amendment to the grant will not be issued). The second (or any subsequent) no-cost extension request will be subject to the approval of an NSF Grants Officer, and, if approved, will be in the form of an amendment to the grant specifying a new end date. Grantees are cautioned not to make new commitments or incur new expenditures after the end date of the award in anticipation of a no-cost extension. In addition, grantees must be aware that most NSF appropriated funds have a limited period of availability for expenditure before the appropriation cancels. No-cost extensions do not extend the period of availability for canceling funds.

The PI and/or Department Administrator must prepare the request with appropriate justification in NSF’s electronic systems and “submit”.  This will generate an email to GCS NSF Grant Administrator who will review and submit to NSF. 

OFFICE OF NAVAL RESEARCH

Prior written approval is required to extend the period of performance, without additional funds, beyond the expiration date of this grant. The Administrative Grant Officer (AGO) at the Administrative Office in Block 23.a. of the ONR Award has authority to approve no funds extension requests meeting all of the following parameters:

  • a one-time basis only; and
  • for a period not to exceed 90 days; and
  • where $50,000.00 or less of obligated funds remain to be expended.

In other cases, where a request is outside of one or more of the above parameters, a no funds extension can only be approved with the concurrence of the Technical Representative cited in Block 21.a. of the ONR Award. 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 23.a. of the ONR Award Form or the Awarding Office in Block 22 of the ONR Award Form.

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.  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 Manager, 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, Ms. Michele Marshall, via email.  If Program Manager approval is not evident, ACO will contact him/her directly.

Remember, that Program Manager approval is not sufficient and Michele Marshall will not give any approval until she has the official request from GCS.  You are cautioned not to make new commitments or incur new expenditures after the expiration date until the official award modification has been received.

Information Needed:

ONR Award #:
PI: 
Program Manager:
WHOI Project #:
Title:
Current Period of Performance:
Requested NEW End Date:
 

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.



Last updated: February 1, 2017
 


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