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Project Delays | Part 2: No Cost Extensions Maintain Research Momentum

This summer, the Spotlight is considering the topic of project delays in funded research. What pitfalls, anticipated or unexpected, can contribute to or cause delays or disruptions? What strategies and tips can be used to either offset or overcome delays? Last month we looked at ClinicalTrials.gov and how its effective use can complement a research project and contribute to its steady progression toward completion. This month, judicious and timely management of no-cost extensions is discussed.

Academic research is unpredictable and subject to unforeseen circumstances.  During the COVID-19 pandemic it seemed that every research project had to go into no-cost extension (NCE) as laboratories were shut down entirely. Researchers were able to use the NCE mechanism as a means to keep their projects afloat during such an unprecedented global event. Typically, an NCE is a request to extend a project’s period of performance (POP) beyond the expiration date without additional funds to provide the principal investigator (PI) more time to complete the project. Ideally, progress and spending are continually monitored to allow plenty of time to plan for that NCE.  Sponsors have limits on how late requests may be submitted and last-minute requests may be denied. In addition to the sponsor deadline for NCE requests, the pre-award office requires lead time to review, check compliance and internal approval, and process the submission. The post-award office may have begun preparing closeout documents and needs time to reverse closeout procedures. Failure to plan ahead for a successful NCE jeopardizes hard-earned research funding.  

Given that NCEs are a fact of life, here are some recommendations to help make the extension process as painless as possible while advancing funded projects to completion. First and foremost, ensure that the sponsor permits no-cost extensions. The award agreement will often indicate whether an NCE is allowable and how much advance notice is required.  Depending on the sponsor, the awardee institution may have an NCE request deadline between 15 and 90 days prior to award expiration.  Federal sponsors usually have standardized procedures while non-federal sponsors can be all over the map, underscoring the need for early planning.  

If an NCE is allowable the following information should be compiled as part of the sponsor request:

• What amount of remaining, unencumbered funding is available?  A budget for the extension period is either desirable or required, depending on the sponsor.  Some sponsors will not accept extension requests with no remaining funds. Others may allow it provided the remaining work requires only time and effort such as writing papers or tabulating data.  In that case it is important to freeze the account to avoid deficit spending during the extension period.
• Will the PI and other key personnel continue to devote the same level of effort during the NCE period?  Contrary to popular belief, sponsors do not assume a reduction in effort.  If effort is to be reduced 25% or more during the NCE, federal sponsors require prior approval. Other sponsors likely have similar expectations.
• Detail pertinent compliance information regarding research protocols (IRB-human subject research, IACUC-vertebrate animal subject research) including the approval number, title, and expiration date.  Research compliance applies regardless of funding status.

What is the justification for the extension?  It is very important to always remember that spending down the remaining funds is not an acceptable NCE justification!  For example, capital equipment is rarely an acceptable purchase during the last or extension period of research.  A large purchase can use up those remaining funds, right?  But logically, the equipment should be used to support research activities during the POP and should have been purchased earlier.  Stockpiling supplies at the end of a project is also a big red flag.  Hence, the justification must be scientific in nature and might result from one of these situations:

• Inability to recruit qualified graduate students and/or post-doctoral fellows;
  • Equipment production or shipment delays;
  • Instrumentation downtime;
  • Transfer, illness, or injury of project personnel;
  • Extended contract negotiations that delayed the ability to start the project;
  • Global or weather event (force majeure);
  • Subcontractor delays due to any of the above;
  • Delays in obtaining specially bred animal subjects (i.e., knockout mice); and
  • Delays in recruiting human subjects.

First No-Cost Extensions
Expanded Authority: Most sponsors participating in the Federal-Wide Research Terms and Conditions supplementing Uniform Guidance allow recipients of grants and cooperative agreements to initiate a one-time NCE of up to 12 months without prior approval unless otherwise noted in the award terms and conditions. Prior approval is required for subsequent extensions.  Non-federal sponsors are case-by case, so consult the award documents or contact the sponsor if clear information is not found.  

Second No-Cost Extensions 
During the pandemic, sponsors were generous in allowing second NCEs due to the pervasive slowdown in research.  They have resumed the practice of less generous allowances. It is never wise to blindside a sponsor. If work has been delayed enough to warrant a second extension, supporting information should be detailed in annual progress reports and discussion about anticipated delays should have taken place prior to submission of subsequent NCE requests.

The most common sponsors are the National Science Foundation (NSF) and the National Institutes of Health (NIH); their requirements are summarized here.  

National Science Foundation
NSF has a subtle but critical piece of information when differentiating between no-cost extension types, Grantee-Approved and NSF-Approved extensions.  For example, a first no-cost extension can go to NSF-Approved status if the request is after the 45-day deadline for automatic approval.  This has tripped up more than one administrator since the text is similar between the two, but the difference is huge.  As with NIH, NSF must approve second NCE requests.  NSF uses Research.gov to request and approve NCEs.   This is spelled out in Chapter VI 3.c and d of the Proposal & Award Policies & Procedures Guide (PAPPG).

National Institutes of Health
NIH requires grantees to use eRA Commons for first NCE requests and the first extension can be grantee approved.  A revised notice of award will not be issued.  Second NCE requests require prior approval where the Authorized Organizational Representative (AOR) signed requests must be submitted in writing to the Grants Management Officer no later than 30 days before the proposed change.  This is described in section 8.1 of the NIH Grants Policy Statement. 

With proper planning, no-cost extensions can be an effective way to successfully complete a research award, preserve precious research funds, and avert delays.  

Authored by

Angela Behrend, Senior Grants and Contracts Administrator, Office of Sponsored Programs
University of Virginia, Charlottesville

Stacy Schwenke, Senior Grants and Contracts Administrator, Office of Sponsored Programs
University of Virginia, Charlottesville