Session 1: Coffee with Colleagues “I have the money but not the time, what do I do?” A conversation on carryovers and no cost extensions January 22, 2018 Hiebert Lounge
Topics Carryover No Cost Extension NIH Process NIH Process • • Examples of NIH Automatic Carryover No Cost Extension Requests Examples of NIH 1 st and 2 nd No Cost • • Examples of NIH Carryover Requiring Prior Approval Extension Requests NSF Process NSF Process Non-Federal Process Non-Federal Process Process for when BU is the subrecipient Process for when BU is the subrecipient 2
Carryover Carryover Unobligated funds remaining at the end of any budget period that, with the approval of the sponsor or under an automatic authority, may be carried over to the next budget period to cover allowable costs of that budget period. 8 Obligated/Committed funds are not considered carryover (for instance, funds already obligated to subcontracts during that period). The term “carry over ” is synonymous with “carry forward ” 3
NIH Process Carryover The Notice of Award (NOA) dictates whether Boston University has automatic carryover or if it requires prior approval. If the carryover is automatic then BU Does the NOA indicate automatic assigns one internal order number carry forward? (IO) for the life of the award. When carryover requires prior approval, separate IOs are created for each year. BU would need to request approval from NIH to carryover funds from the prior year to the current year. Once approved, we would receive a revised NOA, deobligate from the previous IO, and attribute the additional funds to the current IO. Examples of NIH grant mechanisms requiring prior approval are U and P awards. 4
Examples of NIH Automatic Carryover vs. Carryover Carryover Requiring Prior Approval NOA Example of Automatic Carryover NOA Example of Carryover Requiring Prior Approval 5
NIH Automatic Carryover - BU Account Notification (AN) Carryover Yr 2 Yr 1 Same IO Same IO New obligated total with year 2 funds added to IO Comment in AN 6
NIH Carryover Requiring Prior Approval BU AN Carryover Same grant number Yr 2 Yr 1 Different IO Different IO Cumulative obligated amount in Grant. Comment in AN 7
NSF Process Carryover NSF grants are awarded as either a lump sum or incrementally funded awarded. NSF Grants In both cases, automatic carryover is granted and one IO is almost always issued for the life of the award. If NSF restricts carryover, it will be noted in the NOA. automatically carryover NOTE: Restricted carryover for NSF grants is rare 8
Carryover Non-Federal Process The Award Agreement dictates whether Boston University has automatic carryover or if it requires prior approval from the sponsor. Non-federal awards vary The Sponsored dramatically with Programs RA will The department their guidelines If an approval is then submit the and Sponsored thus the required, the information and Programs RA will department department send the determine next should always should provide carryover for steps and seek reference the the required internal approval if Award Agreement information. processing once needed. and discuss with approved by the their Sponsored sponsor. Programs RA. 9
When BU is the subrecipient Carryover Review the NOA to If automatic carryover is not automatically granted to BU, a determine the terms request has to be made to the prime recipient/pass and conditions through entity. associated with carryover. 10
No Cost Extension No Cost Extension A no-cost extension (NCE) extends the project period beyond the original project end date at no additional funding level. Usually occurs when the following conditions are met: • The end of the project period is approaching, AND • There is a programmatic need to continue the research, AND • There are sufficient funds remaining to cover the extended effort *No Cost Extensions should not be requested just because there is money left over, a programmatic benefit must be justified. 11
No Cost NIH Process Extension Example of 1 st NCE in eRA commons 1 st NCE 2 nd , 3 rd NCE Requires additional justification/ prior approval to be submitted to Sponsor approval not required (if NIH. PI discussion with NIH PO is justified and funds are available) recommended Processed in eRA Commons by Requested in writing OSP RA No revised NOA is issued, it is Revised NOA issued reflected in eRA Commons • Boston University requires an Institutional Prior Approval Request (IPAR) form to be completed by the department to initiate the NCE request. This should be completed by the department and sent to Sponsored Programs ospera@bu.edu • Once the NCE is confirmed in eRA commons, Sponsored Programs sends the IPAR/NCE confirmation for internal processing and a revised AN is sent out to the department. 12
NIH 2 nd No Cost Extension Example No Cost Extension 2 nd NCE Letter Example Example of NOA Term 13
No Cost NSF Process Extension Example of 1 st NCE Grantees may authorize a one-time extension of the grant of up to 12 months additional time beyond the established end date. A 2 nd or 3 rd NCE can be requested, but requires additional justification in research.gov. *Grantees are not authorized to extend an award that contains a zero balance. • Boston University requires an Institutional Prior Approval Request (IPAR) for to be completed by the department and sent to Sponsored Programs ospera@bu.edu for internal processing • Once the NCE is authorized by NSF, Sponsored Programs sends the IPAR/NCE confirmation for internal processing. A revised NOA is not issued, it is reflected in research.gov. A revised AN will be issued to the department. 14
No Cost Non-Federal Process Extension Non-federal sponsors vary dramatically when it comes to the procedure associated with requesting a no cost extension. Due to the varying guidelines, the department should always review the award agreement first and discuss with their Sponsored Programs RA. An Institutional Prior The Sponsored Programs The department and Approval Request (IPAR) RA will submit for sponsored programs RA A revised AN is issued to must be completed and internal processing. This determines the next the department after approved by the step may be on hold if steps. Is sponsor the approved NCE is department and sent to we are waiting for approval needed? If processed internally. sponsored programs sponsor approval for the yes… ospera@bu.edu NCE. Non-Federal No Cost Extension Award Example 15
No Cost When BU is the Subrecipient Extension • BU can receive a NCE when the prime organization receives The prime recipient/ a NCE for their project period and is willing to pass it down to the subrecipient. BU can also receive a NCE from the pass through entity prime organization when our project end date occurs before determines if it will the prime recipient’s project end date. grant BU a NCE at • BU’s agreement should be reviewed prior to initiating this the end of our request, the process usually starts with Sponsored Programs reaching out to the prime recipient after discussions with project period the PI/DA. 16
Questions / Resources Link to IPAR Form 17
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