I. What is an NCE?
An NCE is the mechanism by which a Principal Investigator obtains from the sponsor additional time to complete a project where no additional funding is required.
No Cost Extension (NCE) Frequently Asked Questions
NCE FAQs
II. When is an NCE warranted?
Generally
In general, the following conditions should exist to make a strong argument for an NCE:
No additional funds are required, there are remaining funds available in your grant account and the Scope of Work won’t change; AND
- Additional time beyond the established expiration date is required to assure adequate completion of the originally approved project;
- Continuity of support is required while competing continuation application is under review;
- The extension is necessary to permit an orderly phase out of a project that will not receive continued support; and/or
- A late start to the project due to circumstances beyond the control of the Principal Investigator necessitates an extended due date.
An NCE for the purpose of spending down remaining project funds is not appropriate.
Financial Assistance (i.e., Grants and Cooperative Agreements) and Contracts have different rules. See the “Award Type” in Section 12, Basic Award Information, of the Award Review Checklist (which is in Part II of Frevvo) to know what rules apply to your project.
Financial Assistance
2 CFR § 200.308 provides federal agencies with the authority to waive certain prior approval requirements for Financial Assistance recipients. NCEs are listed in 2 CFR § 200.308(d)(2).
Contracts
NCEs for Contracts (federal or otherwise) are very different from NCEs for Financial Assistance awards; NCEs are not automatically available for Contracts. Further, failing to complete the Scope of Work within the Contract’s period of performance may be a breach of contract and may subject Boise State to legal liability. NCEs granted for Contracts will generally be accomplished via formal amendments signed by the sponsor and Boise State.
III. Why do I have to commit effort during an NCE?
You are still working on a funded project, so your effort has to be tracked and included in the whole of your effort report certification. The terms and conditions of your original award — including your original commitment of effort — generally continue unless amended.
NSF-Specific Guidance
“Additional effort on the part of the PI beyond what was initially funded in the proposal is not implied by a no-cost extension. Generally, a no-cost extension is a rearrangement in the timing of when the effort will take place. The two-month commitment originally funded by NSF should be provided for by the awardee institution. However, if the PI was funded two months per year on a three year grant, the PI should provide six total months over the entire award period. A 12 month no-cost extension would not increase the PI effort to 8 total months. It simply provides an additional year in which the originally proposed effort is to take place.” See Section 19 of the Frequently Asked Questions (FAQs) NSF’s Revised Cost Sharing Policy Updated January 2013.
NIH-Specific Guidance
“With the exception of grant programs that have an effort requirement, or where terms and conditions prohibit such reductions, NIH will not require prior approval for the reduction in effort for Senior/Key personnel named in the [Notice of Award]. The recipient is reminded that active awards must have a measurable level of effort.” See NIH Grants Policy Statement Chapter 8.1.1.3.
IV. When can I request an NCE Request and who approves it?
Generally
Financial Assistance (i.e., Grants and Cooperative Agreements) and Contracts have different rules. See the “Award Type” in Section 12, Basic Award Information, of the Award Review Checklist (which is in Part II of Frevvo) to know what rules apply to your project.
Financial Assistance
As soon as you believe you will need an NCE (before the project period ends), you should: (i) discuss it with the sponsor’s Technical Contact; and (ii) submit the NCE request to OSP. Depending on the sponsor’s unique rules and the terms and conditions of the award, OSP may not be able to immediately request the NCE. The rules for certain high-volume sponsors, which are maintained in NSF’s Prior Approval Matrix, are identified in the table below.
| Agency | First NCE | Subsequent NCE(s) | References |
|---|---|---|---|
| NSF | BSU must notify the sponsor at least 10 days before the project period ends. | BSU must request approval from the sponsor at least 45 days before the project period ends. | Section VI.D.3.c of the Proposal & Award Policies & Procedures Guide (PAPPG) |
| DOE* | BSU must notify the sponsor at least 10 days before the project period ends. | BSU must request approval from the sponsor before the project period ends. | Section 3.3, Budget and Project Periods, in the Guide to Financial Assistance |
| NIH | BSU must notify the sponsor before the project period ends. | BSU must request approval from the sponsor at least 30 days before the project period ends. | Electronic Research Administration (eRA) website No-Cost Extensions FInal Budget Period webpage |
| USDA NIFA | BSU must notify the sponsor at least 10 days before the project period ends. | BSU must request approval from the sponsor at least 10 days before the project period ends. | USDA/NIFA Award Terms and Conditions website. Article 2 of USDA/NIFA "Agency Specific Requirements" on NSF's website |
| NASA | BSU must notify the sponsor at least 10 days (but not more than 30 days) before the project period ends. | BSU must request approval from the sponsor before the project period ends. | No-Cost Extensions website |
Contracts
NCEs are for Contracts (federal or otherwise) are very different from NCEs for Financial Assistance awards; NCEs are not automatically available for Contracts. Further, failing to complete the Scope of Work within the Contract’s period of performance may be a breach of contract and may subject Boise State to legal liability.
As soon as you believe you will need an NCE (before the project period ends), you should: (i) discuss it with the sponsor’s Technical Contact; and (ii) submit the NCE request to OSP. Approval for any NCEs granted will be done via formal amendments signed by the sponsor and Boise State.
V. If my NCE is approved, are Subawards automatically extended?
If there are Subawards under this award, they will not automatically be extended. Subrecipients need to request NCEs by contacting OSP Contracting Services at sponsoredagreements@boisestate.edu.
VI. How do I request an NCE?
Submit a Request for No-Cost Extension Form. OSP Contracting Services will make the NCE request for you, and will keep you informed as the request progresses.
If your award allows you to submit an NCE without going through OSP, please copy sponsoredagreements@boisestate.edu on your email to the sponsor. This is important to ensure the timely extension of your award in InfoEd and Oracle Financials Cloud.