No Cost Extension - K05

Purpose

When a project cannot be completed within the specified project period, many sponsors will allow the project to be extended. This is referred to as a no-cost extension (NCE).  A NCE extends the original project period, allowing the completion of project aims without additional funds being provided by the sponsor. There must be a scientific, project-related reason to extend the project end date. Extensions may not be obtained for the sole purpose of spending remaining funds.


Scope

This procedure applies to all sponsored projects subject to OU Policy 19.045 Administering External Grants and Contracts set up as separate accounts in the OHIO Financial Management System (FMS).


Process

For federal grants:

Federal awarding agencies are authorized to waive administrative prior written approvals for no-cost extensions under 2 CFR 200.308(e)(2).  If your award includes this waiver, OU can authorize a one-time no-cost extension for up to 12 months unless one or more of the conditions outlined below apply. For initial one-time extensions, the recipient must notify the Federal awarding agency in writing with the supporting reasons and revised period of performance at least 10 calendar days before the end of the period of performance specified in the federal award. This one-time extension may not be exercised merely for the purpose of using unobligated balances.

Extensions require explicit prior Federal awarding agency approval when:

  • The terms and conditions of the Federal award prohibit the extension.
  • The extension requires additional Federal funds.
  • The extension involves any change in the approved objectives or scope of the project.

Second extensions always require prior written approval from the sponsor. 

For Federal Contracts:

The terms and conditions of the federal contract should be reviewed to determine the allowability and process for a no-cost extension.

Other (Non-Federal) No-Cost Extension Requests

In general, most sponsors will entertain the possibility of extending a project, provided the source of funds can accommodate the revised period of performance.  Submit a request as described below to begin the process.

In all of the above cases, the PI or administrator should initiate a no-cost extension request through LEO as described below.

How to request a NCE:

  • Initiate an Extension Request in LEO.
  • ORSP will link the appropriate transmittal to the request and route for chair and dean approvals.
  • When chair and dean approvals have been obtained, ORSP will determine whether a notification or request should be submitted to the sponsor and work with the PI to create the necessary documentation, which often includes a justification for the extension and sometimes includes a budget reflecting expenses during the extension period.
  • ORSP will submit the notification or request to the sponsor. Some federal agencies use their electronic systems to process no-cost extensions.  NSF uses Research.gov and NIH uses eRA Commons.  Specific information regarding those systems is below.
  • Once approval is granted, ORSP will review all documentation for completeness and route to Grants Accounting.
  • Grants Accounting will update the Financial Management System (FMS).

Specific Instructions:

NSF initial and second no-cost extensions

NIH initial and second no-cost extensions

Extension With Additional Cost

It is possible that you may have the need to request an extension to a project which would require supplemental financial support. If this occurs, the first thing you should do is discuss the technical issues with your technical liaison at the sponsoring agency. You should ask for advice and counsel about the best way to proceed. If you are advised to make a supplemental request for additional support, discuss the situation with your department chair to ensure s/he is in agreement, and then contact your sponsored programs manager to begin to develop a supplemental proposal and budget. A new transmittal form in LEO will be required for this action.


Roles and Responsibilities

OWNER: PI/Co-PI

CONTRIBUTOR: CFAO/BUM, ORSP, Grants Accounting

APPROVER: PI/Co-PI, Department Chair, Dean, Center Director


References

OMB 2 CFR 200.308(d)(2) Revision of budget and program plans, one-time extension


Review/Revision History

Revised 08/17/2022
Created 2021