If project work is on-going and funds remain available to cover project expenses, it may be appropriate to request a no-cost extension. Considerations include award terms, funding for committed effort on the project, timing, and approvals required.
What is the UMB process to extend the budget period in eUMB?
Award terms:
The Coeus Notice of Award should provide information as to whether or not sponsor prior approval for a no-cost extension is required. This information is based on the following review of the award terms and conditions.
Federal grants under the expanded authorities: Most NIH grants and many others allow the University to approve, internally, ONE extension of up to 12 months. Subsequent extensions require sponsor approval. ORD recommends asking for the full 12 months. If the project is completed earlier, the final project report and other final reports may be submitted and the grant will terminate. Or, if a renewal award is made, the sponsor will early terminate the extended award to match up with the start date of the renewal award.
Clinical study agreements: Many CSAs do not include an end date. If there is no specified term of agreement or end date, then the project dates can be extended while the study is active, with internal approval.
Subrecipient agreements, Corporate agreements, Federal contracts, and many other awards: Sponsor approval is required.
Committed effort:
Unless otherwise notified, sponsors, particularly Federal agencies, expect PIs (and other key personnel) to provide the level of effort outlined in proposal budgets. For Federal awards, the Principal Investigator and Key Personnel are expected to maintain the same, committed level of effort throughout a project, including a no-cost extension. If insufficient funds remain to cover salaries for the committed level of effort during the extension period, there are two options:
- Obtain approval for cost sharing, using the “Cost Sharing Commitment Approval Request” form
- Reduce committed effort - Note, however, that if the reduction in effort is >25% of the committed effort, Sponsor approval for the reduction in effort is required.
Timing:
When internal approval is required: Request a no-cost extension 3-6 weeks in advance of the award expiration date
When Sponsor approval is required: Request a no-cost extension 6-8 weeks in advance of the award expiration date
Extensions requiring internal approval only:
No-cost extension form
Submit the completed, signed form to your team in ORD Extensions requiring sponsor approval: - The Principal Investigator writes a letter to the sponsor describing and justifying the request.
- The letter is signed by the PI and by an ORD authorized official. Emails must be initiated (sent) by the PI in lieu of signature.
- The sponsor must approve the request in writing. Sponsor approval is normally provided by the grant or contract officer, and not by a program official. Approval may be in the form of a letter or an award modification.
- When ORD receives the sponsor’s written approval, the document will be processed for extension of the eUMB chartstring budget period.
- In some cases, such as subrecipient agreements, it may be necessary to keep the chartstring active while awaiting the sponsor’s approval. Use the Preaward Spending form and check the box for Extension of Project ID.
For extension of subawards issued by UMB
Once the chartstring has been extended in eUMB, use the Request for Change to Subrecipient Agreement form to request an extension to the subaward, when appropriate. However, ORD does not recommend issuing an extension to a subaward if sponsor approval is required and is still pending. Effort Commitment of PI/Key Persons
Reduction of effort - If insufficient funds remain in the award to cover the committed effort for the PI and Key Persons on a Federal award, it may be necessary to reduce effort of one or more individuals. If the effort will be reduced by <25% of the committed effort, the reduction should be documented in the PI/department project files. If the effort will be reduced by >25% (that is, 25% or more) of the committed effort, sponsor approval is required. - The Principal Investigator writes a letter to the sponsor describing and justifying the request.
- The letter is signed by the PI and by an ORD authorized official. Emails must be initiated (sent) by the PI in lieu of signature.
- The sponsor must approve the request in writing. Sponsor approval is normally provided by the grant or contract officer, and not by a program official. Since this involves PI and Key Person effort, the program official may be asked to weigh in on the request prior to action by the grant or contract officer.
- Ensure that ORD receives a copy of the written response, and retain the documentation in the PI/department project files. At this time, the payroll and effort may be modified.
Cost-share Approval Form – If insufficient funds remain in the award to cover the committed effort for the PI and Key Persons on a Federal award, it may be necessary to request approval for cost sharing.
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