CLARIFICATION ON NSF NO COST EXTENSION (NCE) REQUEST DEADLINES

        There are two possible types of NCE request deadlines for DIRECT NSF awards.  The first type is a NCE under EXPANDED AUTHORITY.  The second is for all NCEs that NSF approves, i.e., Non-Expanded Authority NCE requests.  These are discussed below.  In addition, we have also discussed below certain rules for PASS THROUGH NSF awards.

        THE EXPANDED AUTHORITY NCE REQUEST

        These Expanded Authority NCE requests were not discussed in the DGCA FORUM announcement of February 26, 2004 because the University has the authority to self approve these.  For  this type the NCE the University must notify the NSF ten (10) days prior to the expiration of the award "to ensure accuracy of NSF's grant data."  Many of you refer to these as automatic one-year extensions.  These cannot be approved by the DGCA "merely for the purpose of using the unliquidated balances."  In addition, we can not approve a NCE for "an award that contains a zero balance."  Please see the NSF Grant Policy Manual section 253.2 for the full text.  If an Expanded Authority NCE is submitted after the ten day deadline, it is treated as the second type NCE request wherein the 45 day deadline and rules apply.

        THE NON-EXPANDED AUTHORITY NCE REQUEST

        These were the NCE requests discussed in the DGCA Forum announcement of February 26, 2004 and repeated in its entirety below.

         "For a number of years the NSF deadline for submitting a no-cost-extension (NCE) for an award has been 45 days prior to award end date.  However, due to implementation of Fastlane and other internal NSF matters, NSF has not held colleges and universities to the deadline.  Recently, NSF somewhat modified the approval format and also started enforcing the deadline.  If a NCE is submitted past the deadline, NSF requires, in addition to the reason for the NCE, an explanation why the NCE is being submitted past the deadline.  All NSF NCEs must be approved by the DGCA before they are sent to the NSF. 

        In order for the DGCA to have time to review, approve and send the NCE before the new NSF deadline, we are requesting that all NCEs be entered into Fastlane no later than 60 days prior to the end date of the award.

        While we can't guarantee that they will be accepted, any NCE entered into Fastlane after the 45 day deadline will be processed by the DGCA." 

        PASS THROUGH AWARDS

        Included in this category are awards where Rutgers is the subrecipient.  For example, the prime award could be with Penn State which in turn subawards a portion of the award to Rutgers.  Since Penn State is under expanded authority any NCE request for the "automatic one-year extension" by the Rutgers PI would have to be done with Penn State in time for Penn State to submit the appropriate information via Fastlane to NSF.  If the prime is not under expanded authority all NCE requests must adhere to the non-expanded authority NCE request rules.  If the prime is a SBIR/STTR (Small Business Innovative Research/Small Business Technology Transfer) company by regulation they are not under expanded authority and the 45 day rule applies. 

Ronald S. Thompson, CPA, MBA, Assistant Controller  
Rutgers, The State University of New Jersey         732-932-0165 ext 2218
Division of Grant and Contract Accounting                     Fax 732-932-0182
3 Rutgers Plaza                             E-mail thompson@grantadm.rutgers.edu
New Brunswick, NJ 08901-8559     Web site http://postaward.rutgers.edu

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