When circumstances prevent a Principal Investigator (PI) from achieving his/her project objectives by the award expiration date and awarded funds are still available, the lead PI should consider a no cost extension (NCE). This will allow the PI more time to complete the scope of work without requesting additional funds from the sponsor.
It is very important that the PI involve the Sponsored Project Office (SPO) or the Industry Alliances Office (IAO) (depending on the type of sponsor) in making a request for an NCE. Contracts and Grants Accounting (CGA) will only suspend the fund closeout process (for a pending NCE) or extend the award end date (for an approved NCE) if the NCE request/approval is processed through SPO/IAO.
The following guidelines are provided to assist the PI with requesting an NCE.
The Principal Investigator (PI) is expected to adhere to the award’s approved time line and complete the project’s objectives by the award’s end date. If an NCE is necessary to complete the objectives and funds still remain, the PI should work with SPO or IAO to process a request for an NCE.
SPO/IAO is responsible for making sure that the NCE request from the PI is processed appropriately according to sponsor guidelines. SPO/IAO also is responsible for notifying CGA when an NCE request (processed through SPO/IAO) has been made and/or approved.
CGA is responsible for managing the closeout of all expired awards according to campus timelines and procedures and will only suspend the closeout process (for a pending NCE) or extend the award (for an approved NCE) after receiving proper documentation from SPO/IAO.
When to Request an NCE
It is appropriate to request an NCE for an award that has an approaching expiration date if awarded funds still exist and all project objectives have not been accomplished. Please note: Sponsors expect that the original award terms and conditions will extend throughout the award period, including a no-cost extension period. The reduction in effort of key senior personnel named in the award may require sponsor prior approval. If human subjects or animal research is occurring, it is essential to ensure that protocols are extended for the life of the award, including during the NCE period. The PI should check for conflict of interest (COI) issues that may also need to be addressed based on sponsor policy. Questions related to a potential financial conflict of interest and/or the use of humans or animals as research subjects should be directed to the appropriate committee/offices (e.g., CPHS, ACUC, and COI).
Please note: It is not necessary to request an NCE in between budget periods of a multiple-year award if additional anticipated funding is obligated in the award document and the end date for the authority to spend is earlier than the award expiration date. In such cases spending between budget periods or funding increments will be allowed by CGA at the Department’s/PI’s risk. Any deficit that results will be resolved in accordance with the campus policy on deficit reduction.
How to Request an NCE
The PI should always work with SPO/IAO to request an NCE when this is an appropriate action (see above). Sponsor policy dictates how such a request should be made, and sponsor requirements for requesting an NCE vary. The University may be required to obtain prior sponsor approval for an NCE, or the University may be able to extend the award expiration date without sponsor approval. In some cases the NCE request will need to be signed by the PI as well as countersigned by SPO/IAO and submitted in hard copy to the sponsor. For other requests the PI will need to prepare a request/justification for SPO/IAO to send to the sponsor via email or through an electronic portal provided by the sponsor. For NSF, and other sponsors that require NCEs to be submitted through an electronic system or portal, the PI will need to upload the NCE request into the appropriate portal/system and then notify the SPO Contract and Grant Officer (CGO) that a NCE needs to be processed. Failure to notify the CGO may cause the NCE to be overlooked. In short, the PI should always follow the sponsor’s requirements for submitting an NCE request and discuss this process with SPO/IAO before taking action.
Grantee-Approved No-Cost Extensions (GANCE)
Some federal agencies issue awards with Research Terms and Conditions (RTC) that allow a first-time grantee-approved no-cost extension (GANCE) for a period up to 12 months after the original award expiration date. In such cases SPO can establish a GANCE for the PI without prior agency approval. To ensure that the GANCE can be established and communicated by SPO to CGA before the award closeout process begins, it is recommended that the PI begin working with SPO to process a GANCE at least one month prior to the expiration date of the award.
Procedures for establishing a GANCE vary across federal agencies. For NSF, the PI must upload the NCE request into Research.gov and give “SRO” access so that SPO can process the request. Always contact your SPO CGO to ensure receipt of the NCE request. To process a GANCE for an NIH award, the PI will need to send SPO an email requesting a new award expiration date. This email message must be received directly from the PI’s campus email address (…@berkeley.edu). SPO then will process this request through the eRA Commons. PIs should consult with their SPO CGO for the procedures required by other federal sponsors. In all such cases, the PI should provide SPO with a programmatic justification for the NCE as well as a new award expiration date.
Please note: A GANCE may be requested for a period of up to 12 months. The PI should always request a GANCE for an ample amount of time so a second NCE (requiring sponsor approval) is not required.
Sponsor-Approved No-Cost Extensions
When prior sponsor approval is required for an NCE, it is recommended that the PI begin working with SPO/IAO on an NCE request that conforms to the sponsor’s requirements at least two months prior to the expiration date of the award to prevent the fund from being closed out prematurely. It will be necessary to obtain sponsor approval of an NCE in the following situations:
- A GANCE would have been allowed but was not processed in time to meet the sponsor’s NCE deadline.
- The PI already received a GANCE and needs to request a second NCE.
- The federal sponsor issuing the award does not waive prior sponsor approval for an NCE.
- The award is funded by a non-federal sponsor and the award terms do not explicitly state that the University can extend the expiration date without sponsor approval.
If the sponsor requires a letter request for an NCE, the PI should provide the letter to SPO/IAO in hard copy format and address all of the sponsor’s conditions for requesting an NCE. If the sponsor requires, include a description of the work left to accomplished and an explanation for the funds remaining, if there is a significant amount unspent. The letter should clearly state the requested new award expiration date. An example is provided below. The PI should sign the letter and provide a space for SPO/IAO to add a counter signature from an “Authorized Representative.”
If the sponsor allows for emailed NCE requests, the PI should send an email to SPO/IAO addressing the same elements described above for a letter request. To be accepted by SPO/IAO for processing, the email must be received directly from the PI’s campus email address (…@berkeley.edu).
Processing an NCE
The processing time for an NCE can be immediate or lengthy depending on the practices of the sponsor. GANCE requests typically take less time than requests requiring sponsor approval. However, PIs are encouraged to talk with SPO/IAO about the expected turnaround time for processing any NCE and to plan accordingly.
Typically the sponsor will notify SPO/IAO when an NCE has been processed/approved. If the sponsor notifies the PI instead of SPO/IAO, the PI should contact SPO/IAO immediately. The PI should never submit the sponsor’s approval of an NCE directly to CGA. Failure to submit the sponsor’s approval to SPO/IAO will delay establishment of the NCE and place the fund at risk for premature closeout.
Note: In the event the PI overlooks the need for an NCE and the sponsor’s internal NCE deadlines are missed, the PI should contact SPO/IAO as soon as possible.
SPO/IAO will notify CGA when an NCE is approved. Upon receiving this notification CGA will revise the award expiration date and close-out date accordingly.
SPO/IAO will also notify CGA when an NCE is pending. Upon receiving this notification CGA will place the award fund in a “pending status” for up to 70 calendar days after the original award expiration date. This will allow the PI to continue expending award funds at the risk of the Department/Unit while the NCE is being reviewed by the sponsor.
Sixty (60) calendar days after the original award expiration date, CGA will inform the PI that the internal CGA closeout process will begin in ten (10) calendar days unless notification of NCE approval is received from SPO/IAO. The PI should work with SPO/IAO to obtain sponsor approval so that SPO/IAO can provide this approval to CGA. If NCE approval is not received by CGA at the end of the ten (10) day period, CGA will start the closeout process, adhering to the sponsor’s original schedule and completing the close out of the award at 90 days post-expiration.
After the fund has been closed out, the PI may still reactivate the fund when the outstanding NCE approval is received from the sponsor and processed through SPO/IAO unless sponsor policy prohibits the reestablishment of the fund. Note: If the sponsor does not approve the NCE, any funds spent after the original award expiration date will be subject to the campus’ deficit reduction policy.
Example No-Cost Extension Request
<PI Contact Information>
<Receiver’s Contact Information>
Subject: No-Cost Extension Request for Subcontract <Insert Agreement #>
Dear <Name of Program Officer>,
I wish to request a no-cost extension for <Insert Agreement #/Project Title> awarded to UC Berkeley. The current project end date is <Insert Current End Date>, and I wish to extend the project end date to <Insert New End Date>.
(If required by the sponsor add the following:)
- The total amount of unobligated funds remaining to support this effort is <Insert Remaining Balance>.
- <If balance is remaining is significant, explain why funds have not been spent as planned.>
By extending the end date of the project I will be able to use existing project funds to:
<Describe the remaining work/objectives to be completed during the NCE period.>
Thank you for your time and consideration. Should you have any questions or concerns regarding this request, please feel free to contact me or the University’s Authorized Organization Representative listed below.
|<PI name and title>
||<AOR name and title>
If appropriate, you may wish to provide a space for the Program Officer to approve the request by countersigning the letter of request.