My 2 cents opinion:

Essentially you must give the agency written notice for the first NCX up to 12 months.  Technically you should notify NIH (Commons) two weeks before the expiration date. You are not supposed to grant the NCX just because there’s a balance to be spent. That’s not allowed.  Your first NCX should be (and justified in writing from the PI to your Grants Office) justified that additional work time is needed to complete the research.

That said, the real issue to NIH/Sponsor is who’s going to cost-share that PI’s effort. This is an issue of PI effort at your institution. If the effort for this PI is less than what was originally in the proposal, you need to let NIH/Sponsor know in your written notification.

I don’t remember a 20% threshold for this, but I do remember in the old progress report forms with Project grants NIH wanted to see if the main site or any of any it’s subcontractors were going to use more than 25% balance of the last year’s budget.

To be legalistic, if the terms and conditions of your specific R15 don’t forbid your extending for up to one year and using unobligated balances, then the A-110 clause .25 kicks in to allow it.

See Section .25 in the A-110 where the expanded authorities is referred to (“(d) No other prior approval requirements for specific items may be imposed unless a deviation has been approved by OMB.”)

http://www.whitehouse.gov/omb/circulars_a110#25

Is there such a thing anymore as “unwritten rules” with NIH?

:)

Suzanne Stroud   |  Office of Grants and Contracts
Certified Research Admnistrator, CRA, CPRA
Methodist Hospital Research Institute   |   Texas Medical Center
http://www.methodisthealth.com/tmhri

Phone:  713-441-3931   |   Email:  xxxxxx@tmhs.org
   

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Johnson, Landy (Director of Grant Development)
Sent: Thursday, June 06, 2013 7:28 AM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] No Cost Extensions - Unwritten Rule?

I have a first-time NIH grant PI with a question about an "unwritten rule" on no-cost extensions.  She is requesting her first no-cost extension, and under expanded authority I can grant that to her and enter it in the NIH Commons electronically.  She has been told by other researchers  at a large research university that if she has more than 20% of her funds left it cannot be done this way because she will have to provide justification to NIH.

I cannot find anything anywhere about this alleged 20% rule; in fact a no cost extension is supposed to be based on work remaining to be done, not on funds.  However, I asked her to ask her colleagues where they obtained their information, and they tell her the rule is unwritten.  Before I call NIH and potentially sound like an idiot asking about unwritten rules, I thought I'd ask my wonderful colleagues.

Are you aware of the "unwritten 20% rule?"  If it exists, does it pertain to R-15 AREA grants?  Or, is it a vestige of a pre-expanded-authority world?

Thanks for any help you can provide.

Landy

----------------------------
Landy C. Johnson, MPA, Ph.D.
Assistant Professor of Economics and Geography Director of Grant Development Assumption College Provost Suite
500 Salisbury St., Worcester, MA 01609-1296
508-767-7666
xxxxxx@assumption.edu

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