Saint Louis University

2.23 Guidelines for No-Cost Extensions

SECTION Academic Affairs NO. 2.23
Subject: Guidelines for No-Cost Extensions 11/21/04 12/01/08
  1. Policy
    It is the policy of the School of Medicine to encourage all researchers, either basic or clinical science, to follow the appropriate guidelines established regarding No-Cost (Noncompeting) Extensions on grants.
  2. Purpose
    Per NIH guidelines, the grantee institution is authorized to extend, with or without cost, most previously approved R-series grant award periods (for investigator-initiated, basic research grants) for up to one additional year beyond the originally designated project period termination date. In cases where the extension is made without commitment of additional funds, this is called a “no-cost” (or “noncompeting”) extension. Only grants covered under expanded authorities can receive an institutionally authorized no-cost extension. Grants other than R-series grants, or second no-cost extensions on R-series grants, require NIH approval. Notice of extension must be made through the issuance of a revised Notice of Grant Award. [See “PHS Grants Policy Statement” (April 1994)]
  3. Procedure
    1. Obtaining a No-Cost Extension
      1. 30-60 days before the expiration of the current grant award, the PI should write a memo to the Director of the Office of Research Services (ORS), School of Medicine, requesting a no-cost extension. The memo should include:
        • Principal Investigator (PI) name
        • NIH Grant Number (not the SLU account number)
        • Title of the grant
        • A statement requesting the no-cost extension


            (The following language is provided by the NIH):

          • 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.
          • The extension is necessary to permit an orderly phase out of a project that will not receive continued support.
        • Original start and expiration dates of award
        • Requested date of expiration
        • Upload memo to the original eRS Transmittal Form as a Proposal Related Document.
      2. After the request is reviewed, and if all of the information is correct, the Director of ORS and the School of Medicine Finance Office electronically approves the request. Once an approval of the no-cost extension is granted, the Office of Research Services notifies NIH through the eRA Commons. The system will automatically change the end date for the grant and notify the appropriate NIH staff. A revised Notice of Award will be sent to the PI and the ORS with the new end date. The PI will prepare a Fund Request Form and route to the SLU Finance Office and the ORS, who will inform the Office of Sponsored Programs.
    2. Expenditure of No-Cost Extension Funds
      A. Decisions regarding the expenditure of remaining funds derived from an R-series grant source should be made jointly between the designated Principal Investigator (PI) on the grant and his/her department Chairperson. In general, these funds should be used to further the research program of the PI, as outlined and described in the original grant application submitted for peer review and funded by decision of the relevant Advisory Council of the U.S.P.H.S. funding agency. Normally, the intention is to afford the PI sufficient resources to permit him/her to collect requisite additional experimental data to successfully support a revised competing grant renewal application. Such expenditures may include any of the budgetary categories designated in the original grant application, e.g., salaries and fringe benefits, supplies, animal purchase and per diem costs, equipment, travel, etc. Under normal circumstances (i.e., in the absence of financial exigency), no-cost extension funds should be allocated preferentially to expenditures other than those involving salary/fringe benefit recoveries. In the event that there is a specific need to expend the funds for salary/fringe benefit recoveries, the PI’s department Chairperson will seek to provide the PI with additional, compensatory funds from other available sources to provide for other budgetary categories requisite to substantively support the PI’s research endeavors.
    3. Dispute Resolution
      In the event the PI and his/her department Chairperson cannot come to a mutually satisfactory agreement regarding the expenditure of no-cost extension funds, the dispute will be referred to the Dean of the School of Medicine for resolution.
      1. The PI or the department Chairperson should request, in writing, that the Dean convene an ad hoc Faculty Grievance Committee to review the dispute.
      2. The Dean will refer the matter to an independent, ad hoc Faculty Grievance Committee for adjudication, within 14 calendar days from the date the grievance notification is received.
      3. The ad hoc Faculty Grievance Committee shall consist of three (3) full Professors, none of whom shall have an appointment (primary, secondary, or otherwise) in the same department as the PI and his/her department Chairperson. In addition, each Committee member must be a PI on at least one current or recently funded, substantial, extramural research grant. To avoid even the appearance of a conflict of interest or undue bias, the Committee shall not be comprised of department Chairpersons, Division Chiefs, Institute Directors, or administrative officials of Saint Louis University.
      4. The ad hoc Faculty Grievance Committee shall hear direct testimony from both parties to the grievance (the PI and Chairperson), as well as from other informed parties as may be required or deemed desirable by the Committee. A decision regarding the appropriate expenditure of no-cost extension funds must be made, by simply majority vote, within 30 calendar days of hearing the grievance. The decision will be rendered in writing as a recommendation to the Dean of the School of Medicine, who will then consider the recommendation and render a final decision in the matter within one calendar week of receiving the Committee’s recommendation. Immediately, or as soon thereafter as is practical, that decision will be communicated in writing to both parties involved in the grievance. The decision of the Dean will be considered final, and will not be open to further appeal by either party.
  4. Reference
    "PHS Grants Policy Statement" (April 1994) 
  5. Rescission
  6. Review Date
    Reviewed annually and revised when necessary and appropriate.


    Approved: Philip O. Alderson, M.D., Dean, School of Medicine

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