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No Cost Extension

PPD-0213

PPD Number: 0213
Title: No Cost Extension
Responsible Office: Sponsored Programs
Effective Date: 08/01/2025
Last Updated: First Version

I. Scope

This policy and procedure document (PPD) applies to William & Mary’s Batten School of Coastal & Marine Sciences (Batten School) & Virginia Institute of Marine Science (VIMS)]. It applies to [all members of the Batten School & VIMS community, including faculty, staff, and students]. It applies to all Batten School & VIMS campuses, including the Eastern Shore Laboratory (ESL) and the Kauffman Aquaculture Center (KAC).

II. Purpose & Policy Statement

This policy establishes the procedures and requirements for requesting and processing No-Cost Extensions (NCEs) on sponsored projects at the Virginia Institute of Marine Science (VIMS), in compliance with 2 CFR §200.308(g)(2) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).

Under 2 CFR §200.308(g)(2), VIMS may initiate a one-time no-cost extension of the final budget period of a federal award for up to 12 months without prior approval from the federal awarding agency, provided:

  • The extension does not require additional Federal funds.
  • There is no change in the scope or objectives of the project.
  • The request is made at least 10 calendar days before the project period ends; and
  • The extension is needed to ensure the completion of the originally approved project activities.

III. Responsibilities & Procedures

Responsibilities

  • Principal Investigator (PI): Initiates the NCE request and provides justification.
  • Financial Officer: Assists PI with documentation and internal approvals.
  • Office of Sponsored Programs (OSP): Reviews and processes the request, notifies the sponsor, and ensures compliance with Uniform Guidance.

Procedures

  1. PI-Initiated Request
    • The PI must submit a written request to OSP at least 30 calendar days prior to the project’s original end date, including:
      • Justification for the extension;
      • Length of the extension (not to exceed 12 months);
      • Updated timeline for completion of project goals;
      • Revised budget (if applicable, to reflect how existing funds will be used).
  2. OSP Review and Notification
    • Upon receipt, OSP will:
      • Review the request for compliance with federal guidelines and confirm that:
        • No additional funds are being requested.
        • The scope and objectives remain unchanged.
      • Submit notification to the sponsor, as required by the terms of the award
      • OSP will notify the PI(s) and Financial Officer(s) of the approved extension and will retain documentation for audit purposes.

IV. Limitations, Regulations, & References

Limitations

  • Only one no-cost extension may be authorized internally under this policy.
  • Any subsequent extensions or requests that involve a change in scope or require additional funding must be submitted to the federal sponsor for prior written approval.
  • Awards with specific sponsor requirements that supersede federal guidelines must follow sponsor-specific policies.

Related Regulations & Reference