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No Cost Extensions and other Post-Award Actions

ORBiT Desk Action Queue

A new SPO workflow queue was added to ORBiT in December 2015 to help track SPO Desk Actions, including no cost extensions and other post-award actions. Action items received in the Sponsored Projects Office (SPO) will be entered on the queue and be visible by the Department Liaisons and Analysts according to assigned department. The current status of the action will be noted in the "Where is it" field of the associated ORBiT record number so that the department can track the status. When complete, the action will leave the queue, however a historical record of desk actions will be viewable on the "Proposal Processing" screen of the associated record number. The types of actions tracked on the queue are below.

No Cost Extension

A ​No Cost Extension (​NCE​)​​ is an extension of the period of performance of an award beyond the current expiration date with the purpose of allowing the principal investigator to finalize a project with no additional funds being provided by the sponsor. If additional time is needed to complete the original scope of a project a request for a no cost extension may be submitted to the sponsor. The extension cannot simply be to expend remaining funds.

The department liaison should work with the PI to prepare a NCE request, which is reviewed, endorsed and submitted to the sponsor by SPO. Depending on the sponsor, in addition to the justification for the extension and the proposed new end date, details such as the amount of funds remaining, a budget plan for the use of such funds, and a project progress update, may need to be included with the request.

Sponsors may require extensions be submitted through their electronic systems. Below is information on submitting NCEs to some of UCSB's most common sponsors.

NSF

On certain awards, the NSF allows for a one-time grantee-approved NCE. Subsequent NCEs must be approved by the NSF. NCE notifications and requests are initiated by the PI in Research.gov and forwarded to SPO for review and submission to the NSF. Additional guidance on NSF NCEs can be found in the NSF Award Administration Guide (AAG). The PI's annual conflict of interest disclosure must be up to date in order for SPO to process the NCE.

NIH

Grantees may extend the final budget period of a NIH project when the following conditions are met. No additional funds are required by the NIH awarding office and there will be no change in the project’s originally approved scope. In order to mandate an extension, one of the following criteria must be applicable. Additional time beyond the established expiration date is required to ensure adequate completion of the originally approved project; continuity of NIH grant support is required while a competing continuation application is under review; or the extension is necessary to permit an orderly phase-out of a project that will not receive continued support.

The grantee-approved NCE notification is made in eRA Commons and is accessible by SPO starting 90 days before the original project end date. To request a grantee-approved NCE, the department liaison should forward the PI's justification for the extension and the length of the requested extension, up to 12 months, along with a completed PHS Assurance form to their SPO team. The PI's annual conflict of interest disclosure must be up to date in order for SPO to process the NCE.

Any additional extensions require NIH prior approval and must be submitted as a "prior approval request".

Other Post-Award Actions

Deobligation of Funds

The withdrawal of financial support under an award, in completely or in part, at any time prior to the date of completion. If a sponsor seeks to deobligate funds from an agreement, SPO will consult with the department, PI, and Extramural Funds Accounting prior to accepting the deobligation or negotiating a different outcome with the sponsor. If funds are deobligated from an award, SPO will process an action in ORBiT to lower the award amount to the new, reduced total. A budget allocation will be required from the department and a synopsis will be issued to record the action.

Award Termination

​Award termination is the formal ending or terminating of a research agreement prior to its end date and completion of the scope of work. Award termination can be initiated by the sponsor or UCSB and be the result of one of many different factors. The terms and conditions of an award usually govern the procedures of termination. In the event the PI or department receives a termination notice, please contact your SPO team immediately. SPO will consult and coordinate with the administering department, PI and Extramural Funds Accounting.​​

Award Transfer (Incoming)

Incoming award transfers are treated as proposals. Please see the SPO Proposal Preparation page for information.

Award Transfer (Outgoing)

In the event a PI accepts a position at another institution and will no longer be employed at UCSB, they may request to transfer their award(s) to the new institution. This requires notification of the sponsor, coordination with the new institution and the termination and early closeout of the award at UCSB. Individual sponsors may have specific requirements and mechanisms for transferring an award. Please consult your award terms and conditions and contact your SPO team for assistance.

Please note that awards are issued to UCSB and the campus may elect to retain the award at UCSB instead of allowing it to transfer to the PI's new institution.

Change of Principal Investigator (PI)

In the event a PI or Co-PI will no longer serve that role on a project, a new PI must be selected and approved to lead the project. This could be due to the PI’s transfer to another institution or the PI’s extended disengagement in the project, among other reasons. In virtually all cases, the sponsor must be notified and prior approval of the change received from the sponsor before the change can be made. Please consult the award terms and conditions for the requirements related to changing the PI and contact your SPO team for assistance and to submit the prior approval request. Once the sponsor grants approval, the SPO team will unlock the data sheet so that the department liaison can make the change in ORBiT. When the new data sheet with the signatures of the PI(s) and department chair is provided to SPO, an action will be processed in ORBiT and a synopsis distributed.

Change of Administering Department

An action is done to formalize a change in the administering department/ORU for an award in ORBiT and Accounting's financial system.

To request a change of the administering department/ORU, the current department/ORU should send a memo or email to SPO including identifying award information (award number, sponsor name, etc.). The memo should be signed by the PI and the Chair/Director of both the current and proposed future department/ORUs. If done by email, the email chain should contain the concurrence of the PI and the Chair/Director of each of the two units.

Upon receipt of the memo or email, SPO will change the administering department/ORU in ORBiT on the award's most recent record number. The new department/ORU must then generate and submit a new signed data sheet signed to SPO. When the new signed data sheet is received, the change will be processed in ORBiT, a new synopsis generated, and sent to Extramural Funds accounting to set up the award under the new department/ORU.

Addition of Subaward​

​If it's determined, after an award is issued to UCSB, that a portion of the programmatic effort needs to be performed by another university or entity we may seek permission from the sponsor to add a subaward to that entity. In most cases, prior approval to add a subaward is required if that subaward was not included in the proposal. The department and PI should consult the award terms and conditions and the subaward page of the SPO website for guidance. A subaward proposal, consisting of the required UCSB subaward forms, subawardee scope of work and subawardee budget should be forwarded to the department's SPO team along with any required prior approval request.

Request to Rebudget

​As a research project progresses, the PI may determine that the goals of the project are best met by spending the award funds differently than originally proposed. Awards have specific requirements related to how the funds may be spent. The sponsor may allow deviation from the proposed budget without receiving notice or granting prior approval, may restrict any deviation from the proposed budget without sponsor approval, or apply limited restrictions to rebudgeting. If the rebudgeting also involves a change in the scope of work, additional approvals may be required.

Before rebudgeting, review the terms and conditions of the award. If prior approval from the sponsor is required, the department and PI should prepare and forward a prior approval request to their SPO team. The SPO team will review the request and submit it to the sponsor.

If sponsor approval is not required for rebudgeting, the department and PI should work directly with Extramural Funds Accounting to rebudget the funds.

Pre-Award Spending

There are times when it is in the best interest of the project to spend funds prior to the award period start date. An example is when equipment needs to be ordered so that it is available for use at the beginning of the project. Prior approval from the sponsor is necessary before spending funds before the start date. Some sponsors automatically allow pre-award spending during a certain period before the start date. The department and PI should consult the award terms and conditions for the requirements particular to their award. If prior approval is required, the department or PI should forward the prior approval request to their SPO team for review and submission to the sponsor. If the sponsor does not require prior approval, the department should forward the PI's request to their SPO team for processing in ORBiT.

For information regarding a Request to Approval to Spend funds before an award is received or finalized, please see the Pre-Award Spending page.

Request to Carry​-forward Funds

​Some awards restrict spending to a specific budget period and funds remaining at the end of the budget period cannot be automatically "carried forward" to be spent in the next budget period. Prior approval from the sponsor must be obtained in order to retain the unspent funds and use them in the next period. The award terms and conditions should specify if automatic carry-forward is allowed or if prior approval is necessary. Additionally, as an extra reminder to the administering department and PI, award condition code 40 is usually included on the synopsis of awards that restrict carry-forward of funds. If prior approval is required, the department and PI should work with their SPO team to submit a prior approval request.

Prior Approval Request Procedures

Many sponsors require that we seek and receive prior approval before making changes to the budget or scope of work of a project. The award terms and conditions should state when prior approval is required and outline specific requirements for making the request. Generally, the sponsor wants to know what change is being requested, why it is being requested and what effect it may have on the project. If the request is budget related, the sponsor may require a copy of the proposed new budget. The prior approval request should be forwarded by the department or PI to the SPO team for review and submission to the sponsor. The procedures for prior the NIH and NSF are detailed below.

NIH Prior Approval Request

All requests for NIH awarding IC prior approval must be made in writing (including submission by e-mail) to the NIH Grants Management Officer (GMO) no later than 30 days before the proposed change, and signed by SPO. If the request is e-mailed, it must provide evidence of SPO's approval; a cc to SPO on an email submitted directly to the NIH is not acceptable.

Please forward the PI's request to SPO for review, endorsement and submission to the NIH GMO. The GMO will review the request and respond to SPO with copies to the PI and the Program Officer.

For additional information, please see the Changes in Project and Budget section of the NIH Grants Policy Statement. If uncertain about the need for prior approval, contact your SPO Team who, in turn, may consult with the GMO.

NSF Prior Approval Request

Notifications and Requests must be submitted by SPO to the NSF via Research.gov, which the NSF is transitioning to from Fastlane. Currently, Fastlane is used for Cost Sharing notification and requests to Add a Subaward, PI Transfer and Change PI or Add/Change a Co-PI.

Requests should be initiated in the appropriate electronic system and forwarded to SPO for review and submission to the NSF.

Page updated 3/18/2016

 

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