No-Cost Extension Request Procedures

Page Updated: August 26th, 2019

In order to request a no-cost extension (NCE) for all sponsored projects, please use the following instructions to guide you through the process. Notably, a no-cost extension must be requested in advance of the end date of the award (but typically not earlier than 90 days before the end date) based on agency requirements. All requests and materials (as applicable) should be routed through WISPER.

An initial no-cost extension request may only require that UW-Madison notify the sponsor (known as a grantee-approved no-cost extension). Any requests submitted after the sponsor’s designated deadline must be approved by the sponsor. Any second or third no-cost extension request must be approved by the sponsor and may require submission of information such as a progress report and budget/budget justification, in addition to the NCE request itself.

Note that ANY charges incurred after the official end date of the project and before receipt of the Sponsor's final approval are the responsibility of the PI and the Department (like expenses on an account-in-advance). See RSP Notice 2011-2, Financial Responsibility for Uncollectable Costs on Extramural Projects.

Step 1: Reviewing Commitments

With the exception of grant programs that have a specific minimum effort requirement, RSP no longer requires the update of effort commitments when requesting or receiving a no-cost extension. After a thorough analysis of sponsor polices and Federal regulations, it has been concluded that a no-cost extension simply provides additional time in which the originally proposed effort can take place. More information on this can be found here.

Normally, there is no need to adjust commitments during an NCE period. However, there might be rare instances when a commitment is necessary during the NCE period. Specific grant programs may require a specific minimum effort requirement, which should continue in the NCE period. Before preparing the NCE request, review the terms and conditions of your award to determine if a specific commitment must continue.

At this time, RSP is aware of only a few NIH grant programs that require a specific minimum effort requirement. They include NIH award types:

• K awards: PIs are required to devote a minimum of 9 calendar months to the award. Prior approval is required to reduce effort during a no-cost extension period. (See NIH GPS guidance.)
• R35: Minimum effort is described in Funding Opportunity Announcement (search for FOA).
• DP1: Minimum effort is described in Funding Opportunity Announcement (search for FOA).

If submitting a no-cost extension for an award that requires a minimum effort commitment during the NCE period (regardless of whether the NCE requires sponsor approval), please submit a separate prior approval request if you wish to reduce an effort commitment. See instructions.

• For most awards:
• When requesting an NCE, you do not need to address effort commitments.
• RSP will not adjust commitments in SFS during the no-cost extension period.
• If a minimum commitment is a requirement of the award terms and conditions:
• This should be mentioned in the Comments Tab of the WISPER record.
• In these few instances, RSP will make the update to the commitment in SFS appropriately.

Step 2: Preparing & Routing the Request

The WISPER record should be completed including:

• On the General Tab, complete the basic information, including the following highlighted sections:
  

  
  Also be sure to address:
  • Protocols: Respond and provide related approval numbers and dates, if applicable
  • Budget Amount: Can be blank
  • Outgoing Subawards: Respond as applicable
• On the Project Details Tab:
• All fields (except for budget and commitment details) must be completed to prevent errors on the record.
• No commitment information is needed, unless otherwise required. See Step 1 above.
• On the Attachments Tab:
• No-cost extension request letter (signed by PI) (not required for first NSF NCE request - see below)
• A PI signature may be necessary based on your Division's requirements - please consult with your Dean's office
• Divisions should use the SUBMIT TO SPO function

The following bulleted list must be addressed in the no-cost extension request. This information should be entered into the attached request letter. (Please use the below Letter Template and put the letter on departmental letterhead. Once prepared, please convert the document to PDF.)

Letter Template

• Agency award reference number and UW Madison Award ID (MSN#)
• Principal investigator name and contact information
• Project title
• Current award period and proposed end date
• Signatures (not required for email or electronic signature if available) from the principal investigator, RSP, and sponsor representative

The letter/email should also include a clear justification statement, summary of progress to date, estimate of funds remaining, what the funds will be used on, a confirmation of continued invoice schedule (if necessary), and timetable for completion of the project.

For NSF: Use Research.gov to prepare a new request for a no cost extension (NCE). The PI must be the one to initiate the request. Enter your information for the no cost extension via Research.gov including the justification text and remaining balance. Forward the no cost extension request within Research.gov to the AOR (i.e. RSP). A WISPER record is still required. Enter the NSF Award Number within the Sponsor Reference Number field on the WISPER record General tab. The number of previous NCE submissions for the NSF award will dictate whether or not a letter is also required, see below:

• If this is the first NCE (which is grantee-approved), then a letter is not required.
• If this is the second or additional NCE (which requires NSF approval), a letter is necessary. Attach the letter to the WISPER record.

Provisional Extensions: The provisional no-cost extension is available for exceptional requests where sponsor approval is needed and UW-Madison is unable to submit the materials in a timely manner.

In these extenuating circumstances, in order to ensure uninterrupted activity, a provisional extension request may be submitted.

• Create the WISPER record per Step 2 above
• The Division should "REQUEST ADVANCE ACCOUNT OF SPO" rather than "SUBMIT TO SPO." This indicates that the Division has not completed the process as described above, and the request letter is not yet ready.
• Based on this "ADVANCE" Division request, RSP will refrain from initiating the closeout process and facilitate whatever systematic changes need to be in place to continue activity/spending.
• RSP will notify campus of the accepted provisional NCE by sending a PROVISIONAL EXTENSION Award Email.

The expectation is that an official no-cost extension request will eventually be submitted to the sponsor, and the actual project and award end dates will be updated upon the Sponsor’s approval of the extension request.