Before You Get Carried Away Planning a No-Cost Extension

Lately, we’ve seen several principal investigators (PIs) make the same administrative oversight involving no-cost extensions and unobligated funds from earlier budget periods.

There’s a bit of nuance here, so it’s helpful to start with definitions:

• Budget period—the time interval from the start date of a funded portion of an award to the end date of that funded portion (usually 12 months) during which recipients are authorized to expend the funds awarded. For example, an R01 with a 5-year project period has five distinct budget periods: Year 1, Year 2, Year 3, Year 4, and Year 5.  
• Prior approval—written approval by an authorized NIAID official evidencing the Institute’s prior consent before a recipient undertakes certain activities or incurs specific costs.
• Carryover—unobligated federal funds remaining at the end of any budget period that, with appropriate approval, may be brought forward to another budget period to cover allowable costs of that budget period.
• No-cost extension (NCE)—an extension of a project or budget period for up to 12 months to complete the work of the grant under that period, without additional federal funds or competition.

Unobligated funds from previous budget periods, e.g., $30k unspent from Year 2 of a 5-year U19 cooperative agreement, are not by default part of the available balance in later budget periods, e.g., Year 5. They must first be carried over.

A PI can carry over funds independently if the award has automatic carryover authority; otherwise, NIAID’s prior approval is required to roll unobligated balances into a subsequent budget period. Automatic carryover authority is common among some activity codes (e.g., R01) and rarely allowed among others (e.g., U19, P30). If you aren’t sure whether your award provides automatic carryover authority, check the Notice of Award (Section III. Standard Terms and Conditions) in eRA Commons or ask the grants management specialist assigned to your award.

Generally, a recipient can initiate the first NCE without NIAID’s prior approval (exceptions are noted below). The funds available during the NCE are the same as what was already available during the final year of the award’s project period, since technically an NCE extends the final budget period (rather than, say, creating an additional budget period.)

Because the first recipient-initiated NCE does not require prior approval, some PIs have assumed that carryover of unobligated funds into that NCE likewise does not require prior approval. But in many cases that is incorrect. Grants without automatic carryover authority can utilize only those funds already indicated on the final budget period’s Notice of Award (refer to 25. Total Federal and Non-Federal Approved this Budget Period on Page 1). In order to spend unobligated funds from an earlier budget period during an NCE, absent automatic carryover authority, you would first need to confirm NIAID’s prior approval of the carryover.

If you’ve already requested and received approval for unobligated funds to be carried over into your final budget period and then you initiate an NCE, those carried over funds will remain available during the NCE period as well.

Suppose you received an administrative supplement in an earlier budget period and have unobligated funds. Since administrative supplements are restricted to the purpose for which they were awarded, they cannot be rebudgeted without NIAID’s prior approval. Any time you submit a carryover request, you should identify if all or a portion of the funds are from an administrative supplement. Keep in mind, NIAID does not award new administrative supplements in the last year of a competitive segment except in rare circumstances, e.g., orderly closeout of a clinical trial.

See Prior Approvals for Post Award Grant Actions SOP for instructions on submitting a prior approval request.