Requesting a No-Cost Grant Extension

A National Background Check Program (NBCP) grantee State may request a no-cost grant extension if it requires additional time beyond the established expiration date (project end date) to fully complete the program plan and objectives proposed in its original grant application, or accomplish orderly phase-out of the project. This resource page provides the Centers for Medicare & Medicaid Services’ (CMS) Office of Acquisition and Grants Management (OAGM) guidelines for submitting such requests.

How do I know whether my State is eligible to request a no-cost grant extension?
When should my State submit a request for a no-cost grant extension?
To whom do I submit the request for a no-cost grant extension?
What are the requirements for submitting a request for a no-cost grant extension?
What happens after my State submits a request for a no-cost grant extension?
What if I have additional questions?
Additional Resources

How do I know whether my State is eligible to request a no-cost grant extension?

CMS has issued a memo altering the requirements for no-cost grant extensions (see Additional Resource 1). Since the memo was issued, fifth and sixth year extensions have also been made available. A grantee State that received a 24 month award under the first solicitation is eligible to request up to four, one-year no-cost grant extensions for a total grant length of 72 months. Grantee States that received 36 month awards under later solicitations are eligible to request up to three, one-year extensions for a total grant length of 72 months. The fact that funds remain at the expiration of the grant is not, in itself, sufficient justification for a no-cost extension.

When should my State submit a request for a no-cost grant extension?

A written request must be submitted to the OAGM no later than 60 calendar days prior to the expiration date of the project period, but no earlier than 120 calendar days prior to the expiration date of the project period.

To whom do I submit the request for a no-cost grant extension?

No-cost extension amendments must be submitted through the GrantSolutions Amendment Module, which is accessed via the new amendments section. Under the “Select Amendment Type,” please select “Extension without Funds.” Your submission will follow the same format as other prior approval requests and must include a cover letter with written justification on company letterhead, signed by the Principal Investigator/Program or Project Director (PI/PD) and the Authorized Organizational Representative (AOR). Specific instructions for submitting the NCE amendment in GrantSolutions can be found in Additional Resource 2 below.

What are the requirements for submitting a request for a no-cost grant extension?

Additional budgetary requirements and considerations are outlined below:

The cover letter (signed by the AOR and PI/PD) must clearly identify:

  • the awardee’s name;
  • title of the project;
  • proposed new project period end date (up to 12 months);
  • the cooperative agreement number;
  • timeline for completion of proposed activities;
  • estimated unobligated balance from the current budget year and prior year(s); and
  • justification for the NCE.

 

Written justification for an NCE must include:

  • proposed activities based on the Program’s requirements or programmatic goals;
  • include a description of how an extension would further your goals;
  • specific challenges that limited progress;
  • an explanation for why these challenges could not be resolved prior to the grant end date;
  • a strategy plan with solutions to address each of the challenges you listed; and
  • a timeline to complete the specified requirements or programmatic goals.

 

Recipients must also complete the SF-424A and upload a new Excel budget workbook with justification supporting up to 12 months of activity reflecting how the recipient intends to use any estimated unobligated funds during the NCE period. The estimated unobligated funds should reflect budget needs for the proposed extension period. Recipients must provide a justification along with a detailed breakout of costs in the budget narrative/workbook to expedite review by CMS. Any costs incurred by the recipient without prior approval from the Grants Management Officer (GMO) will be disallowed.

 

Once you have compiled all required materials noted above, you may submit the NCE amendment to GrantSolutions for review. If your NCE is approved, previously awarded funds may be spent after the current end date. Your requested expenses must comply with the cost principles set forth in HHS regulations at 45 CFR Part 75, Subpart E, which states that the costs:

  • must be allowable and consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the organization;
  • must be in accordance with generally accepted accounting principles (GAAP);
  • must be allocable to the grant program and cost objective under cost principles and can be reasonably distributed in proportion to the funding received;
  • must be reasonable for the performance of the award and must not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time of the decision to incur the costs; and
  • must be necessary for the operation of the organization and the performance of the award.

 

What happens after my State submits a request for a no-cost grant extension?

The OAGM will review the request and follow up with the grantee State as needed. States whose requests are approved will receive a Notice of Award (NoA) signed and dated by the CMS Grants Management Officer (GMO). Only an approved NoA signed by the GMO is to be considered valid and official. Grantee States who take action on the basis of letters or emails from unauthorized officials, including, but not limited to the CMS PO or CMS Program Offices, do so at their own risk. Correspondence from unauthorized officials will not be considered binding by or upon CMS or the U.S. Department of Health and Human Services.

What if I have additional questions?

Please submit any questions you may have to your CMS PO and the OAGM Grants Specialist (Karen Johnson, karen.johnson1@cms.hhs.gov).

Additional Resources

  1. Review/Clearance of Class Deviation Requests for no-cost extensions for the CMS Nationwide Program for National and State Background Check Grants under the Affordable Care Act (ACA) memo. Accessed at: http://bgcheckinfo.cna.org/sites/default/files/public/Scanned_document_18-04-2013_13-17-27.pdf
  2. Instructions on Submitting a No-Cost Extension Amendment Request in GrantSolutions
  3. SF-424a - Budget Information (non-construction programs). Accessed at http://apply07.grants.gov/apply/forms/sample/SF424A-V1.0.pdf
  4. Illustration of a sample detailed budget and narrative justification with guidance for completing SF 424A: Section B for the budget period. Accessed at http://bgcheckinfo.cna.org/sites/default/files/public/sample_budget.docx