Justification Nation: No Cost Extensions

We recently worked very hard to obtain no-cost extensions on a number of grants for several faculty we work with, and it was very difficult, and it’s taking longer to get approvals for these extensions. When you make your case to your grants officers, it’s best to be buttoned up.

These particular faculty thought of NCE’s in the same way that I would imagine other faculty might – the funds are left over, they need the funds to finish their work, and how hard could it be to write a letter and receive approval to use the funds, right? Eh – not always. We just had a no-cost extension take five months to approve!

SOME COMMON MISTAKES FACULTY MAKE AND HOW YOU CAN HELP THEM:

We are working with a faculty member now who is under her first NCE. She’s still confused about it. Admittedly, no-cost extension is not the best name for this time period. This faculty member thought that because she didn’t receive additional money that the rules of the grant aren’t extended during this period – and we quickly disavowed this notion!  Of course, for  as long as the no-cost extension is in effect, the rules of the grant are extended and the expectation is that all milestones are to be met.

Another common misconception is that the purpose of a no-cost extension is that the faculty member is able to obtain the remaining funds in order to finish their work for however long the remaining funds last. No, no, NO!

The purpose of a no-cost extension is to complete the scientific aims of the grant – if there are funds left to complete the work, that’s fine, but sometimes there are not. A no-cost extension can be requested in either case. It should be requested to complete the aims of the grant, for the time period needed (a year or less).  Do not – EVER – justify a no-cost extension by asking to spend remaining funds. The request needs to be driven by the work remaining to do and the personnel and resources needed to accomplish that work.

The justification for a no-cost extension comes down to this: How does the use of the remaining funds help to accomplish the scientific aims of the grant?

Be sure to outline this carefully, before the project close date, so that the funds are available to you just prior to the close of your award. Careful tracking and a thoughtful justification can help you support your PI as you work to fully utilize the awards your PI has worked hard to earn.

4 thoughts on “Justification Nation: No Cost Extensions”

  1. Love your website and the great information on it…thanks! It occurred to me though that it might be helpful to differentiate between NCEs that grantees can approve under the expanded authorities from those that require sponsor approval. What made me think of this is a paragraph from the NSF Award and Administration Guide that states:

    (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.

    I’m not aware of any situation involving a need for a no-cost extension where all funds already have been spent and a zero balance remains, but people should know that, at least for NSF, there HAS to be funds remaining in order to have a grantee-approved no-cost extension.

  2. Franc: Totally fantastic to receive your feedback, and thanks for the NSF perspective. Under expanded authority, there is a similar process for awards under FDP – the first one-time extension, as you describe for NSF – works similarly. There is one difference however under most FDP agencies, and that is an NCE can be granted when there is a zero balance. The purpose of an NCE is not to expend the funds, but to complete the scientific aims. Therefore, the fund balance is irrelevant. However, in NSF’s case, they are concerned about documenting cost sharing of any kind, so one can see why they would be concerned about allowing an NCE in this case. Thanks for your comment!

  3. We just recently ran into a case where the SO thought that a No Cost Extension meant that we wouldn’t be spending any more of the funds, therefore “no cost”. This was quickly corrected!

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