No-cost Extensions

Additional Links: 

NCE Checklist
NCE Request Form available via SPS Web Awards module
Important information related to NCE Requests

Please visit http://grantsupport.duke.edu (link is external) for new information and updates to help with your NIH No Cost Extension (NCE) and Carryover requests.

While it is the sponsor’s expectation that programmatic work will be completed by the project’s end date, occasionally extra time is needed to complete project objectives. If approved by the sponsor, a no-cost extension (NCE) allows additional time to complete the existing scope and objectives of the project without the need for additional funds to do so. Although a NCE may not be requested for the sole purpose of expending remaining funds, it is allowable to expend remaining funds during the NCE period. A NCE request may require prior approval from the sponsor (Sponsor Approved) within a specific timeframe. Under certain circumstances and under expanded authority, the institution is authorized to approve a NCE up to one full year (Duke Approved). The type of approval (Duke Approved or Sponsor Approved) depends on the type of award and any sponsor-specific terms, conditions or policies.  

If one or more of the following conditions apply, the sponsor may not approve the NCE request.

  • the terms and conditions of the award prohibit the extension
  • the extension requires additional federal funds
  • the extension involves any change in the approved objectives or scope of the project
  • the extension is requested after the end date of the award
  • this is the third request for a NCE

At least 90 days prior to project end date: Grant Manager should run the “Projects Approaching End Date” report in Duke @ Work (link is external) to identify upcoming closing projects. For any projects appearing on this list, Grant Managers should reach out to the PI to determine if a NCE is needed and appropriate. For those projects requiring additional time to complete, Grant Manager should review sponsor-specific guidelines and project award documents for appropriate procedures for requesting a NCE. Additionally, the checklist above provides a general list of questions and actions that Grant Managers should review and confirm when requesting a NCE.  

Agencies generally do not approve a no-cost extension longer than twelve months. If the University approves a request for an extension of less than twelve months and the PI subsequently wishes to lengthen that time period to a total of twelve months or longer, agency approval must be sought.

SPECIAL NOTES

For a first no-cost extension the request must include two statements:

  1. a brief description of the work that remains to be done
  2. a description of why the work was not accomplished on time
  3. the level of effort of the PI during the extension

A second no-cost extension must include four statements:

  1. a brief description of the work that remains to be done
  2. the level of effort of the PI during the extension
  3. the approximate unobligated balance
  4. a budget for the extension period

Procedures for Obtaining a No-cost Extension

After determining who has the authority to approve the NCE, the Grant Manager initiates the request in SPS Awards and routes it for internal work flow.

For “Duke Approved” NCEs: Upon review and approval of the request, ORA/OR S/DOCR will update the status in SPS to “Duke Approved” and notify TBS to update the project end dates. The Grant Manager who initiated the NCE Request Form will receive an email notification upon this status update which indicates that work and spending can continue on the project. Contact TBS for SAP or ORA/ORS/DOCR for SPS if the project end dates have not been updated within 5 business days from email notification.

If warranted, the form will be “Returned for Changes” or “Denied” with comments from ORA/ORS/DOCR.

For “Sponsor Approved” NCEs: Upon institutional review and approval of the request, ORA/ORS/DOCR will update the status in SPS to “Approved for Sponsor Submission”. If contact information has been provided by the Department, ORA/ORS will request the NCE according to sponsor guidelines and copy or notify the Grant Manager who initiated the NCE Request Form on any email correspondence. ORA will also copy gcmail@mc.duke.edu (link sends e-mail) .

If ORA/ORS is to make the request to the sponsor, the Department must provide the appropriate name(s) and email address(es) of the sponsor’ s Administrative contact(s). For example, for NIH, provide the name and email address of the Grant Management Specialist (GMS). If others are to be copied on the request, those names and email addresses will need to be provided as well. This information should be communicated in the Internal Comments of the NCE Request Form. Any undeliverable emails will be forwarded to the Grant Manager for Departmental follow up with the appropriate sponsor contact. Any additional correspondence or messages unrelated to the NCE should be addressed by the Department.

If the Department is to make the request to the sponsor, they must copy their ORA/ORS administrative contact. For ORA, gcmail@mc.duke.edu (link sends e-mail) should also be copied.

If warranted, the form will be “Returned for Changes” or “Denied” with comments from ORA/ORS/DOCR.

Once the sponsor approval is received, ORA/ORS/DOCR will update the status to “Sponsor Approved”, notify TBS to update the project end dates, and attach final sponsor approval documentation in the SPS Award record. The Grant Manager who initiated the NCE Request Form will receive an email notification upon this status update which indicates that work and spending can continue on the project. Contact TBS for SAP or ORA/ORS/DOCR for SPS if the project end dates have not been updated within 5 business days from email notification.

Departments are responsible for initiating any follow up needed if a response from the sponsor is not received. Requests in the “Approved for Sponsor Submission” status are outstanding, and Departments can monitor requests in this status for their BFRs along with a time stamp of when the approval was requested. Engage with your preaward office for assistance as needed.

For Industry Contract NCEs: The SPS NCE Request Form should be used for extensions to industry contracts that do not have a definitive end date (e.g.., “study will continue until all work complete”). Follow the general guidelines for submitting a “Duke Approved” NCE request. Rev.

If the industry contract has a definitive end date, any sponsor-initiated extension will be treated as an amendment and managed through the contracting process at The Office of Research Contracts. No NCE Request Form is needed in this case and ORA/DOCR will extend the project period in SPS and will send the documentation to TBS for fund code extension once the amendment is fully executed. If, however, both parties’ obligations under the contract have been met and final payment received, then no amendment from the sponsor is necessary and the extension request should proceed through the “Duke Approved” NCE request process in SPS. The finality of the contract with the sponsor should be documented in the NCE request justification.

Extending external subawards: Preaward offices will issue new external subawards with extended end dates for all subs that are receiving NCEs within 6 weeks of submission of SIR (ORA) or subrecipient progress report (ORS).

Discontinuing Closeout Notifications: Submission of the NCE Request Form serves as notification to the Implementation Teams to disable Closeout Notifications System (CONS) notifications. A separate communication to the Implementation Teams or OSP is no longer needed.

Associated Resources

Additional Resources: No-Cost Extension Checklist Video No-Cost Extension: SPS Web Request Form Quick Reference Guide Rev.

ROLES AND RESPONSIBILITIES

DEPT checks the ORS New Award Notification for sponsor's no-cost extension requirement.

If sponsor approval is required... If sponsor approval is not required...

DEPT

  • Writes letter requesting permission to extend the project end date

  • Sends letter to ORS

ORS

  • Reviews the letter and confirms the terms and conditions

  • Co-signs letter and returns to DEPT

DEPT or ORS

  • Forwards request to sponsor

DEPT or ORS

  • Receives sponsor's approval

DEPT

  • Updates the NCE tool in the Award Module of SPS

  • Routes to ORS

ORS

  • Reviews NCE documents and approves

  • Updates SPS Award Module

  • Sends NCE documents to TBS

DEPT

  • Submits request through NCE tool (in the Award Module of SPS) to ORS

ORS

  • Confirms the terms and conditions

  • Reviews and approves the request

DEPT or ORS

  • Notifies the sponsor that Duke is utilizing NCE

ORS

  • Sends NCE documents to TBS

TBS

  • Revises SAP to reflect the new project end date

DOCUMENTATION: OFFICES OF RECORD
ORS and OSP
  • Both keep record of approval in award file