No Such Thing as a Free NCE
In case you missed it, Joe Schumaker wrote a good piece this month aligning requests for no cost extensions with the classic Dickens novel, Oliver Twist. Here’s your bottom line: there can only be one (yes, that was a Highlander reference riffed from a Dickens reference. All about the classics today, folks).
NIH provides an “expanded authorities” clause in almost all Standard Terms of Award that waives the requirement for prior approval No Cost Extension (NCE), among other actions. If the text of the award allows, the grantee is permitted one NCE (that is, to extend the final budget period of a grant’s project period by up to 12 months, with no new funds). This is usually done within 90 days of project end, when the Extension link appears in the “Action” column of the “Status” search results screen. Anything beyond that one request will require permission.
As NIH adjusts NCE guidelines to meet the requirements outlined in the Uniform Guidance, they have audibly noticed an increasing trend of people asking for NCEs in the middle of the project period. You can do this, but this is your one shot. That is: if you get a permitted NCE in the middle of your project period, you won’t see your Extension link at the end of your project period; you’ve already used your expanded authority, even though you had to obtain permission to do so. Further, if you choose not to use the entire allowable 12 months (like you ask for, say, a 4 month extension), you can’t ask for the remainder of what’s allowable (8 months, in this case) without permission: it still counts as a second extension.
So, Warriors, be careful what you wish for; beyond that, know what you’re wishing for. If you’re unsure of your best strategy, let us know: we’ll help you talk it out and figure what’s best for you!