NIH no-cost extension guidance

No Cost Extensions: NIH allows NoA recipients a ONE-TIME authority to extend their grant up to 12 months (may request by month increments anywhere from 1 to 12 months) from the original expiration date stated in the NoA without additional funds obligated to the award. Please note: No Cost Extensions (NCE) are allowed under expanded authority as part of the NIH Standard Terms of Award when there is no change in scope, NoA special terms and conditions do not restrict authority, and activity code permits extensions (i.e., Fellowship F series does not allow NCE).

Criteria for NCE 

• More time is needed beyond the awarded expiration date to adequately complete the original aims approved for the grant
• Continuity of support for existing award while renewal (Type 2 competing continuation) is going through the review process
• Additional time is necessary to phase out the grant in order to closeout the aims

First NCE Request Submission Process

A first NCE submission is electronically performed by the No Cost Extension function via eRA Commons. The NCE feature becomes available within the eRA Commons system 90 days prior to the original awarded expiration date. An NIH No Cost Extension Request Form will need to be completed and submitted via e-mail to the appropriate/assigned ORA Grants Specialist at least 10 days prior to the original expiration date to accommodate a review and approval of extension action. As only individuals with the Signing Official (SO) role may submit extensions in the eRA Commons system, an ORA director will process the extension action. Once the extension action is performed, eRA Commons will automatically update the project and budget period to the new extension end date.

If the original awarded end date was missed without NCE action and it is needed retroactively, a letter will need to be created indicating the NCE request new end date signed by the PI and sent via e-mail to the appropriate / assigned ORA Grants Specialist to review and approve with ORA countersignature. ORA will submit letter to the assigned NIH Grants Management Specialist for extension approval.

Second and Third NCE Request Submission Process

A letter will need to be generated and signed by the PI for submission to ORA for countersignature. ORA will submit the letter to NIH for approval. The request for extension should be submitted to NIH at least 30 days prior to the current NCE project period expiration date to comply with NIH specifications. There are more requirements to include in the second and third request for extension. Please ensure the following information is provided to receive approval:

1. Indicate the estimated unobligated balance amount remaining on the grant
2. Incorporate the unobligated balance amount level into a detailed budget to demonstrate how remaining funds will support the proposed plan for extension
3. Address effort levels for Key Personnel during the requested extension period
4. Provide updated active approval certifications for IRB and/or IACUC protocols as applicable to human subject and vertebrate animal involvement
5. Indicate the scientific rationale for project continuation
6. Provide a detailed justification as to why the project will require more time to finalize from the approved end date

A remaining balance of funds at time of project period expiration does NOT serve as an adequate stand alone justification for NCE. Please refer to the Criteria for NCE for guidance on acceptable instances for NCE. 

Terms and Conditions during the Approved No Cost Extension Period

• All terms and conditions addressed in the NoA and stated in the NIHGPS remain in effect during the extension period.
• Current approved effort levels for Key Personnel remain in effect during the extension period. If a significant reduction of effort is needed for a key person on the grant, it will be considered a Change in status requiring NIH prior approval in accordance with the NIHGPS Prior Approval Requirements.